People vs. Iligan

A person who commits a felony is criminally liable for the resulting death even if the immediate cause of death is a different wrongful act, provided the death is the direct, natural, and logical consequence of the felony committed. The hacking of the victim's head on a national highway was the proximate legal cause of death when the victim, felled by the blow, was run over by a vehicle moments later.

At around 2:00 a.m. on August 4, 1980, Esmeraldo Quinones, Jr. and his companions, Zaldy Asis and Felix Lukban, were walking home from a barrio fiesta dance in barangay Sto. Domingo, Vinzons, Camarines Norte. In front of the Almadrones ricemill, they encountered Fernando Iligan, his nephew Edmundo Asis, and Juan Macandog. Edmundo Asis pushed them aside, prompting Zaldy Asis to box him. Felix Lukban told the group of the accused that they had no desire to fight. Upon seeing his nephew fall, Fernando Iligan drew a bolo from his back and hacked at Zaldy Asis but missed. The trio fled, pursued by the three accused for about half an hour, passing by the house of Quinones, Jr. They stopped only upon seeing they were no longer being chased. After resting briefly, Quinones, Jr. invited his companions to accompany him to his house so he could change into working clothes for his job as a bus conductor.

While the trio were walking toward Quinones, Jr.'s house, the three accused suddenly emerged on the roadside and, without a word, Fernando Iligan hacked Quinones, Jr. with his bolo, hitting him on the forehead and causing him to fall. Horrified, Felix Lukban and Zaldy Asis fled to a distance of about 200 meters but returned after hearing shouts of people, including someone shouting "May nadale na." On the spot where Quinones, Jr. was hacked, they found him already dead with his head busted. They helped the victim's brother carry him to their house. That same day, Dr. Marcelito E. Abas, the municipal health officer, autopsied the body at Funeraria Belmonte in Labo, Camarines Norte. The postmortem report revealed that the 21-year-old victim sustained shock and massive cerebral hemorrhages due to multiple fractures of the entire half of the frontal left, temporal, parietal, and occipital bones of the head, with massive maceration of brain tissue, as well as an incised wound at the right eyebrow and abrasions on the left shoulder and right side of the neck. The death certificate, however, indicated the cause of death as "shock and massive cerebral hemorrhages due to a vehicular accident."

The defendants denied perpetrating the crime and claimed they were in their respective houses at the time. Fernando Iligan testified that he left his house around midnight to fetch visitors at the dance hall, met his nephew Edmundo Asis along the way, and invited him to come along, but they never reached the dance hall because Edmundo was boxed by someone he had sideswiped. Iligan instead brought his nephew home, was overtaken by Juliano Mendoza whom he invited to help cook, and arrived at his own house between 1:30 and 2:00 a.m. Edmundo Asis corroborated this account, testifying that he said "Sorry, pare" to the person he sideswiped but was boxed on his left face, fell, and was helped by Iligan. After Iligan and Mendoza left his house, he slept and woke up at 7:00 the following morning.

The defense made capital of Dr. Abas's testimony that the victim died of a vehicular accident, an opinion the physician had placed in the postmortem examination report based on what he considered tire marks on the victim's left shoulder and right side of the neck. Dr. Abas also testified that the incised wound at the right eyebrow could have been caused by a sharp bolo but was too superficial to have caused death. Circumstantial evidence supported the vehicular accident theory: prosecution witness Zaldy Asis told the victim's father that "before Esmeraldo Quinones (Jr.) was run over by a vehicle, he was hacked by Fernando Iligan," though when asked why he mentioned an automobile, Zaldy said he did not notice any vehicle but mentioned it "because his head was busted." Defense witness Marciano Mago, the barangay captain, testified that at the scene he saw bits of the victim's brain scattered across the road where he also saw tire marks. The prosecution, through the victim's father, presented evidence that Iligan authored the maceration, with the father testifying that from his house about five meters from the road, he saw Iligan holding a bolo as he, together with Asis and Macandog, chased someone, and later heard Iligan say, "Dali, ayos na yan." The trial court found the victim's head was "chopped," resulting in splattering of brain, but the Supreme Court noted this testimony came from a biased witness and was uncorroborated.

• Alibi: Appellants maintained that they were in their respective houses at the time the crime was committed, with Iligan claiming he was home by 1:30 to 2:00 a.m. after bringing his nephew home and cooking with Juliano Mendoza.
• Vehicular Accident as Cause of Death: Appellants argued for the second time on appeal that Quinones, Jr.'s death was caused by a vehicular accident, relying on the testimony of prosecution witness Dr. Abas, who swore that the multiple fractures on the victim's head were caused by a vehicular accident, an opinion he had earlier put in writing in the postmortem examination report.
• Innocence: Appellants professed innocence of the crime for which they were convicted.

• Proximate Cause: Whether the hacking perpetrated by Iligan was the proximate cause of the death of Quinones, Jr. such that Iligan remains criminally liable despite the victim having been run over by a vehicle.
• Treachery: Whether the qualifying circumstance of treachery was properly appreciated given the suddenness of the attack.
• Evident Premeditation: Whether the aggravating circumstance of evident premeditation was established by the prosecution.
• Conspiracy: Whether conspiracy was sufficiently proven to hold Edmundo Asis liable as co-conspirator.
• Damages for Unrealized Income: Whether the award of P256,960 for the victim's unrealized income was supported by sufficient proof.

• Proximate Cause: Yes. Iligan's hacking of the victim's head, though not the direct cause, was the proximate legal cause of death, the vehicle running over the victim being a natural and probable result of the assault committed on a national highway.
• Treachery: No. Suddenness of the attack alone does not establish treachery; there must be proof that the mode of attack was consciously adopted to render defense impossible or difficult, and the prior chase had placed the victim's group on guard.
• Evident Premeditation: No. The prosecution failed to prove the time the accused determined to commit the crime, any act manifesting adherence to that determination, and a sufficient lapse of time for reflection.
• Conspiracy: No. Mere presence, knowledge, acquiescence, or approval without cooperation or agreement to cooperate does not constitute conspiracy; Asis took no active part in the infliction of the wound.
• Damages for Unrealized Income: No. The Court found insufficient proof to warrant the award of P256,960 for the victim's unrealized income.

• Proximate Cause: Under Article 4 of the Revised Penal Code, criminal liability is incurred by any person committing a felony although the wrongful act done be different from that which he intended. The requisites are: (a) that an intentional felony has been committed, and (b) that the wrong done to the aggrieved party be the direct, natural, and logical consequence of the felony committed. The intentional felony was the hacking of Quinones, Jr.'s head by Iligan with a bolo. Although Dr. Abas considered the incised wound superficial, what is material is that by the instrument used and the location of the wound — directed at the head, a vital and delicate part of the body — the assault was meant to do away with the victim. The hacking occurred on a national highway where vehicles are expected to pass any moment. A vehicle passed seconds later, when Lukban and Zaldy Asis, having run about 200 meters, heard shouts. The victim, weakened by the hacking blow which sent him to the cemented highway, was run over. The sequence of events from Iligan's assault to the time the victim was run over, given the very short span of time, constituted one unbroken chain. Applying the doctrine that "he who is the cause of the cause is the cause of the evil caused," Iligan could not escape liability. The hacking was the proximate legal cause — that acting first and producing the injury by setting other events in motion, all constituting a natural and continuous chain, the final event immediately effecting the injury as a natural and probable result.

• Treachery: The lower court appreciated treachery based on the suddenness of the attack. However, suddenness alone does not by itself show treachery. There must be evidence that the mode of attack was consciously adopted by the appellant to make it impossible or hard for the person attacked to defend himself. In this case, the hacking of Edmundo Asis by Iligan followed by the chasing of the trio by Iligan's group was a warning to the deceased and his companions of the hostile attitude of the appellants, placing the group of Quinones, Jr. on guard for any subsequent attacks. Because the victims were forewarned, the element of treachery was absent.

• Evident Premeditation: The prosecution failed to prove all three requisites: (a) the time when the accused determined to commit the crime; (b) an act manifestly indicating that the accused had clung to their determination to commit the crime; and (c) the lapse of sufficient length of time between the determination and execution to allow reflection upon the consequences of the act. Absent these requisites, evident premeditation could not be appreciated.

• Conspiracy: Edmundo Asis did not take any active part in the infliction of the wound on the head of Quinones, Jr. which led to his being run over and consequent death. The testimony that Asis was carrying a stone at the scene was uncorroborated and came from an undeniably biased witness — the victim's father. While Asis, as Iligan's companion, must have known of Iligan's criminal intent, mere knowledge, acquiescence, or approval of the act without cooperation or agreement to cooperate is not enough to constitute one a party to a conspiracy. There must be intentional participation in the act with a view to the furtherance of the common design and purpose. Mere presence at the scene of the crime did not make Asis a co-conspirator, co-principal, or accomplice.

• Damages for Unrealized Income: The Court found insufficient proof to warrant the award of P256,960 for the victim's unrealized income, and the same was disallowed.

• Proximate Legal Cause — Defined as that acting first and producing the injury, either immediately or by setting other events in motion, all constituting a natural and continuous chain of events, each having a close causal connection with its immediate predecessor, the final event in the chain immediately effecting the injury as a natural and probable result of the cause which first acted, under such circumstances that the person responsible for the first event should, as an ordinarily prudent and intelligent person, have reasonable ground to expect at the moment of his act or default that an injury to some person might probably result therefrom. The Court applied this doctrine to hold that Iligan's hacking of the victim's head on a national highway was the proximate cause of death, the vehicle running over the fallen victim being a natural and probable consequence.

• Article 4, Revised Penal Code (Criminal Liability for Felony Though Wrongful Act Be Different) — Criminal liability is incurred by any person committing a felony although the wrongful act done be different from that which he intended. The essential requisites are: (a) that an intentional felony has been committed, and (b) that the wrong done to the aggrieved party be the direct, natural, and logical consequence of the felony committed by the offender. The doctrine that "el que es causa de la causa es causa del mal causado" (he who is the cause of the cause is the cause of the evil caused) underpins this provision.

• Conspiracy Requires Intentional Participation — Mere knowledge, acquiescence, or approval of the act without cooperation or agreement to cooperate is not enough to constitute one a party to a conspiracy. There must be intentional participation in the act with a view to the furtherance of the common design and purpose. Mere presence at the scene of the crime does not make one a co-conspirator, co-principal, or accomplice.

• Treachery Requires Conscious Adoption of Mode of Attack — Suddenness of an attack does not by itself show treachery. There must be evidence that the mode of attack was consciously adopted by the accused to make it impossible or hard for the person attacked to defend himself. Where prior hostile acts placed the victims on guard, treachery is absent.

• Requisites of Evident Premeditation — Three elements must be proven: (a) the time when the accused determined to commit the crime; (b) an act manifestly indicating that the accused had clung to their determination to commit the crime; and (c) the lapse of sufficient length of time between the determination and execution to allow the accused to reflect upon the consequences of the act.

• "Under Article 4 of the Revised Penal Code, criminal liability shall be incurred 'by any person committing a felony (delito) although the wrongful act done be different from that which he intended.'" — This passage states the controlling statutory basis for holding Iligan liable for the victim's death even though the immediate cause was a vehicular accident, not the hacking itself.

• "Proximate legal cause is defined as 'that acting first and producing the injury, either immediately or by setting other events in motion, all constituting a natural and continuous chain of events, each having a close causal connection with its immediate predecessor, the final event in the chain immediately effecting the injury as a natural and probable result of the cause which first acted, under such circumstances that the person responsible for the first event should, as an ordinarily prudent and intelligent person, have reasonable ground to expect at the moment of his act or default that an injury to some person might probably result therefrom.'" — This is the canonical formulation of proximate legal cause adopted by the Court, frequently cited in subsequent jurisprudence on causation in criminal liability.

• "mere knowledge, acquiescence or approval of the act without cooperation or agreement to cooperate, is not enough to constitute one a party to a conspiracy. There must be intentional participation in the act with a view to the furtherance of the common design and purpose." — This passage articulates the standard for conspiracy liability, distinguishing mere presence or knowledge from intentional participation, and was the basis for acquitting Edmundo Asis.

• People vs. Ural, 56 SCRA 138 (1974) — Cited for the doctrine that "el que es causa de la causa es causa del mal causado," supporting the application of Article 4 of the Revised Penal Code.
• People vs. Mananquil, 132 SCRA 196 (1984) — Cited for the essential requisites of Article 4: (a) that an intentional felony has been committed, and (b) that the wrong done be the direct, natural, and logical consequence of the felony.
• Urbano vs. Intermediate Appellate Court, 157 SCRA 1 (1988) — Cited for the definition of proximate legal cause, itself quoting Vda. de Bataclan vs. Medina, 102 Phil. 181.
• People vs. Gadiano, 115 SCRA 559 (1982) — Cited for the proposition that suddenness of attack does not by itself establish treachery.
• People vs. Crisostomo, 160 SCRA 47 (1988) — Cited for the requirement that the mode of attack must be consciously adopted to render defense impossible or difficult for treachery to attach.
• People vs. Batas, 176 SCRA 46 (1989) — Cited for the three requisites of evident premeditation.
• People vs. Izon, 104 Phil. 690 (1958) — Cited for the principle that mere knowledge, acquiescence, or approval without cooperation does not constitute conspiracy.

• Article 4, Revised Penal Code — Provides that criminal liability is incurred by any person committing a felony although the wrongful act done be different from that which he intended. Applied to hold Iligan liable for the victim's death caused by a vehicle, because the hacking was the intentional felony that set in motion the chain of events leading to death.
• Article 249, Revised Penal Code — Defines and punishes the crime of homicide. Applied as the proper conviction after treachery and evident premeditation were ruled out, reducing the crime from murder to homicide.
• Article 64, Revised Penal Code — Governs the application of penalties when neither aggravating nor mitigating circumstances are present. Applied to fix the penalty at reclusion temporal medium, there being no mitigating circumstances.
• Indeterminate Sentence Law — Applied to impose an indeterminate penalty ranging from prision mayor as minimum to reclusion temporal medium as maximum.

Gutierrez, Jr., J., and Bidin, J., concurred. Feliciano, J., was on leave.