People of the Philippines vs. Aniceto Martin

Where death results as the direct consequence of illegal violence, the mere fact that the diseased or weakened condition of the victim contributed to death does not relieve the aggressor of criminal responsibility. Thus, Martin remained liable for parricide although Laura's heart failure was precipitated by fright or shock from the strangulation.

Aniceto Martin, a twenty-eight-year-old farmer of Barrio No. 12, Laoag, Ilocos Norte, courted Laura for several months and was accepted; after premarital sexual intercourse she became pregnant, and they married on June 7, 1948, continuing to live as husband and wife.

Aniceto Martin, twenty-eight years old, was a farmer living in Barrio No. 12, Laoag, Ilocos Norte. He courted Laura Liz of the same barrio for several months and was accepted; they had sexual intercourse before marriage, and she became pregnant. In an advanced stage of pregnancy, she came to live with the defendant's family and demanded marriage, which was solemnized on June 7, 1948; they continued to live as husband and wife.

Between four and five o'clock in the morning of August 1, 1948, Laura's corpse was found inside the family toilet, which was at a certain distance from their home, with a maguey rope, six meters long and one centimeter in diameter, around her neck, leaving a circular mark around it except at the nape, which was unmarked due to her long and thick hair. The corpse was first seen by Anselma Martin, the accused's sister, who was living in the same house, and by Saturnino Tumaneng, Laura's brother-in-law, who happened to be passing by. The defendant was absent from home.

The barrio lieutenant immediately reported the matter to the chief of police, who, accompanied by a policeman, came to the barrio that same morning. When the chief of police arrived, the defendant had not yet returned home. A relative looked for him and found him in a farm at a considerable distance from the defendant's house, and brought him to the latter. Upon being interrogated by the police officer, the defendant at first denied any knowledge of the event, but later promised to make a statement in the municipal building. The police took possession of the rope and put the defendant in a jeep bound for the municipal building. There the defendant made a confession in the Ilocano language, which he signed and swore to at about noon before the provincial fiscal at the latter's house.

In that confession, Martin stated that at about four o'clock in the morning of August 1, 1948, he awoke and his wife also awoke; she asked why he seemed to have no interest in her, and he replied that he did not love her with intent to marry her because he was not the author of her pregnancy. He then went down to their closet west of the house for a major personal necessity, and his wife followed with a rope. As he was in the act of ejecting waste matters inside the toilet, she placed the rope around his neck; he gripped and removed it, asking why she did so, and she replied because he did not love her. He snatched the rope and placed it around her neck, tightening it with his two hands until she died, then laid her at the foot of the door of the closet with her head towards the east and left for the country. He stated that nobody knew or saw what he had done, that he had no companion or preconcerted plan with his sister Anselma Martin and mother Ciriaca Tomas, that he became obfuscated when she placed the rope around his neck, and that he was not compelled, threatened, maltreated, or remunerated but spontaneously made the declaration, which he willingly signed in the presence of witnesses.

Dr. Roman de la Cuesta, resident physician of the Ilocos Norte Provincial Hospital, performed an autopsy on the corpse on August 1, 1948, at 9 o'clock a.m. at the request of the Chief of Police of Laoag. The certificate listed findings of acute dilatation of the heart; enlarged malarial spleen; pregnancy, eight months, female fetus; almost circular contusion around the neck, absent in the occipital region; and no evidence of strangulation in the lungs. In his opinion, the cause of death was acute dilatation of the heart (heart failure). He testified that Laura must have died five or six hours before he examined her corpse at about nine o'clock in the morning; that the cause of death was heart failure due to fright or shock; that the deceased was eight months pregnant; that there was no expulsion of the fetus; and that the fetus must have been alive at the time of Laura's death. At the trial, the defendant testified that while he was moving his bowels in the toilet with his back toward the door, he felt that a rope was being put around his neck from behind. He forthwith snatched the rope and wound it around the neck of the person who had attempted to strangle him upon knowing who that person was. The person fell, and upon looking at her he found that it was his wife.

The trial court rejected this version, finding it unbelievable because, although it was dark, his wife must have shouted or given some sign of who she was when she felt the rope tightening around her neck, and because the version was contrary to his freely given spontaneous confession before the chief of police and sworn to before the provincial fiscal. The trial court also found a motive in the fact that the defendant married Laura unwillingly due to fear of being sued, because he suspected that he was not responsible for her pregnancy.

• Cause of Death: Appellant contended that the death of Laura was not due to the strangling, but to her heart disease.
• Defense Version: At trial, appellant testified that while he was moving his bowels in the toilet with his back toward the door, he felt a rope being put around his neck from behind; he forthwith snatched the rope and wound it around the neck of the person who had attempted to strangle him upon knowing who that person was, and the person fell and turned out to be his wife.

• Scope of Review: Whether the charge of abortion may still be considered on appeal.
• Cause of Death and Criminal Responsibility: Whether Laura's death was caused by strangulation or by her heart disease, and whether appellant is criminally responsible for parricide.
• Proximate Cause and Pre-existing Illness: Whether the victim's pre-existing heart condition absolves appellant of criminal responsibility when death resulted from fright or shock caused by the strangulation.
• Credibility of Defense: Whether appellant's trial version—that he acted upon being strangled from behind—can be believed against his spontaneous confession.
• Mitigating Circumstances and Penalty: Whether the mitigating circumstances of incomplete self-defense and lack of instruction were properly considered in imposing the penalty.

• Scope of Review: No. The charge of abortion was not considered because appellant was acquitted of it; review was confined to parricide.
• Cause of Death and Criminal Responsibility: Yes. The death was caused by strangulation; the heart failure was due to fright or shock caused by the strangling, so appellant directly caused her death.
• Proximate Cause and Pre-existing Illness: Yes. Appellant remains responsible; where death results as the direct consequence of illegal violence, the diseased or weakened condition of the victim contributing to death does not relieve the aggressor.
• Credibility of Defense: No. The trial version cannot be believed; it is contrary to his spontaneous confession, and there was no reason to suppose that the chief of police or the provincial fiscal had any motive for wringing from him a forced false confession.
• Mitigating Circumstances and Penalty: Yes. The trial court considered two mitigating circumstances—incomplete self-defense and lack of instruction—without aggravating circumstances; the judgment was modified to impose twelve (12) years of prision mayor to twenty (20) years of reclusion temporal, indemnity of P6,000, accessory penalties, and costs, without subsidiary imprisonment in case of insolvency.

• Scope of Review: The Court stated that it would not consider the charge of abortion as appellant was acquitted of it, confining review to parricide.
• Cause of Death and Criminal Responsibility: The autopsy found an almost circular contusion around the neck, absent in the occipital region, and no evidence of strangulation in the lungs; the physician opined that death was due to acute dilatation of the heart. The physician testified, however, that the heart failure was due to fright or shock caused by the strangling. The Court reasoned that the heart failure was due to the fright or shock caused by the strangling, and consequently the defendant was responsible for the death notwithstanding the fact that the victim was already sick. Had not the defendant strangled the deceased, the latter, notwithstanding her illness, would not have died; the defendant directly caused her death.
• Proximate Cause and Pre-existing Illness: The Court relied on People vs. Reyes, 61 Phil. 341, 343, which held that a person is responsible for the consequences of his criminal act and even if the deceased had been shown to be suffering from a diseased heart, the appellant's assault being the proximate cause of death, he would be responsible. It also relied on U.S. vs. Brobst, 14 Phil. 310, which established that where death results as the direct consequence of the use of illegal violence, the mere fact that the diseased or weakened condition of the injured person contributed to his death does not relieve the illegal aggressor of criminal responsibility.
• Credibility of Defense: The trial version could not be believed because, although it was dark, his wife must have shouted or given some sign of who she was when she felt the rope tightening around her neck. The version was also against the freely given spontaneous confession made before the chief of police and sworn to before the provincial fiscal. There was no reason for supposing that either the chief of police or the provincial fiscal had any motive for wringing from him a forced false confession. The motive for the killing was found in the fact that the defendant married Laura unwillingly due to fear of being sued, because he suspected that he was not responsible for her pregnancy.
• Mitigating Circumstances and Penalty: The trial court considered two mitigating circumstances in favor of the defendant: (1) unlawful aggression on the part of the deceased without any sufficient provocation on the part of the defendant—which in this case is equivalent to incomplete self-defense on the part of the defendant, he should not have wound it around her neck and tightened it—and (2) lack of instruction, without any aggravating circumstances to offset them, the penalty next lower in degree should be imposed, which is that of reclusion temporal. The Supreme Court modified the judgment appealed from by imposing the penalty of from twelve (12) years of prision mayor to twenty (20) years of reclusion temporal, with the accessory penalties of the law, to indemnify the heirs of the deceased in the sum of P6,000, without subsidiary imprisonment in case of insolvency, and to pay the costs.

• Proximate Cause and Pre-existing Condition — Where death results as the direct consequence of illegal violence, the mere fact that the diseased or weakened condition of the injured person contributed to his death does not relieve the illegal aggressor of criminal responsibility. The Court applied this doctrine because Laura's heart failure was caused by fright or shock from the strangulation, making Martin responsible despite her pre-existing illness.
• Criminal Responsibility for Consequences of Unlawful Act — A person is responsible for the consequences of his criminal act; if his assault is the proximate cause of death, he is responsible even if the deceased had a diseased heart. The Court found Martin's strangulation to be the proximate cause of Laura's death.
• Credibility of Spontaneous Confession Against Later Defense — A spontaneous confession made before the chief of police and sworn to before the provincial fiscal, absent evidence of coercion, may be credited over a later inconsistent defense version. The Court disbelieved Martin's trial claim that he acted upon being strangled from behind.
• Mitigating Circumstances of Incomplete Self-Defense and Lack of Instruction — The trial court considered unlawful aggression on the part of the deceased without sufficient provocation as equivalent to incomplete self-defense, and lack of instruction; with no aggravating circumstances, the penalty was lowered. The Supreme Court modified the penalty accordingly.

• "Where death results as the direct consequences of the use of illegal violence, the mere fact that the diseased or weakened condition of the injured person contributed to his death, does not relieve the illegal aggressor of criminal responsibility." — This passage, quoted from U.S. vs. Brobst, states the controlling doctrine on proximate cause and pre-existing illness that the Court applied to sustain Martin's conviction.
• "A person is responsible for the consequences of his criminal act and even if the deceased had been shown to be suffering from a diseased heart (which was not shown), appellants assault being the proximate cause of the death, he would be responsible." — Quoted from People vs. Reyes, this formulation reinforces that criminal liability attaches when the unlawful assault is the proximate cause of death, regardless of the victim's diseased heart.
• "It should be noted, however that the heart failure was due to the fright or shock caused by the strangling, and consequently, the defendant was responsible for the death, notwithstanding the fact that the victim was already sick." — This is the Court's own application of the proximate-cause rule to the autopsy findings, holding Martin directly caused Laura's death.
• "This version cannot be believed, for although it was dark, his wife must have shouted or given some sign of who she was when she felt the rope tightening around her neck." — This passage explains why the Court rejected Martin's trial testimony that he acted upon being strangled from behind, preferring the spontaneous confession.

• People vs. Reyes, 61 Phil. 341, 343 — Cited for the rule that a person is responsible for the consequences of his criminal act and, even if the deceased had a diseased heart, the appellant's assault being the proximate cause of death, he would be responsible.
• U.S. vs. Brobst, 14 Phil. 310 — Cited for the doctrine that where death results as the direct consequence of the use of illegal violence, the diseased or weakened condition of the injured person contributing to death does not relieve the illegal aggressor of criminal responsibility.
• U.S. vs. Luciano, 2 Phil. 96; U.S. vs. Lugo & Lugo, 8 Phil. 80; U.S. vs. Rodriguez, 23 Phil. 22 — Cited in support of the same proximate-cause principle.

Paras, C.J., Feria, Pablo, Bengzon, Tuason, and Montemayor, JJ., concur.