People vs. Quianzon

One who inflicts an injury on another is guilty of homicide if the injury contributes mediately or immediately to the death of the victim, even though other causes—including the victim's own conduct during a paroxysm of pain—cooperated in producing the fatal result. The victim's removal of a medical drainage tube, done involuntarily due to the pathological condition and pain caused by the wound, does not constitute an independent intervening cause that would reduce the crime to physical injuries.

The accused, Juan Quianzon, and the victim, Andres Aribuabo, were both present at a novena held on February 1, 1934, in the house of Victoria Cacpal in a barrio near the poblacion of Paoay, Ilocos Norte. Quianzon appeared to have charge of the food in the kitchen, and Aribuabo repeatedly approached him to ask for victuals. The case was tried in the Court of First Instance of Ilocos Norte under the Revised Penal Code's provisions on homicide and physical injuries.

On February 1, 1934, a novena for the suffrage of the soul of a deceased person was being held in the house of Victoria Cacpal in a barrio near the poblacion of Paoay, Ilocos Norte, attended by relatives and friends. Between three and four o'clock in the afternoon, Andres Aribuabo went to the kitchen to ask Juan Quianzon for food. It was the second or third time Aribuabo had approached Quianzon with the same request. Greatly peeved, Quianzon took hold of a firebrand and applied it to Aribuabo's neck. Aribuabo ran to the place where the people were gathered, exclaiming that he was wounded and was dying. Raising his shirt, he showed those present a wound in his abdomen below the navel. Aribuabo died as a result of this wound on the tenth day after the incident.

There was no conflict between the prosecution and the defense regarding these facts; the question was who wounded Aribuabo. The prosecution presented four witnesses. Simeon Cacpal claimed to have witnessed Quianzon wound Aribuabo in the abdomen, but the Supreme Court found his testimony so improbable, incongruent, and contradictory that it disregarded his testimony entirely. Roman Bagabay testified that he saw Quianzon apply a firebrand to Aribuabo's neck, that Aribuabo shortly afterward named Quianzon as his attacker, and that Quianzon, when immediately asked by Bagabay about the incident, admitted having attacked Aribuabo with a bamboo spit. Gregorio Dumlao, a barrio lieutenant and nephew of the accused, conducted an investigation upon being informed of the incident; Aribuabo told him the accused had wounded him, and Quianzon in turn stated he had wounded the deceased with a bamboo spit. Juan Llaguno, chief of police of Paoay, questioned Quianzon, who confessed to having applied a firebrand to Aribuabo's neck and later wounding him with a bamboo spit; however, before the chief of police could reduce the confession to writing, Quianzon retracted the admission regarding the bamboo spit. In the affidavit marked Exhibit B, the fact of having applied a firebrand to Aribuabo's neck was admitted, but not the wounding with a bamboo spit.

The defense consisted simply in denying that Quianzon had wounded the deceased and that he had confessed to the witnesses Bagabay, Dumlao, and Llaguno. The defense also contended that even if Quianzon inflicted the wound, the crime should be only serious physical injuries because the wound was not necessarily fatal and the deceased would have survived had he not twice removed the drainage tube that Dr. Mendoza had placed to control the infection. The physician who examined the wound testified that it was a penetrating abdominal wound that perforated the large intestine, causing infection from fecal matter, and that the patient might have survived had he not removed the drainage. The defense itself characterized the victim as mentally deranged.

• Credibility of Prosecution Witnesses: Petitioner argued that the testimony of Simeon Cacpal was improbable, incongruent, and contradictory, and that the lower court erred in considering it. He further contended that the other prosecution witnesses—Bagabay, Dumlao, and Llaguno—were discredited by Cacpal's testimony that he had not seen them speak to either Aribuabo or Quianzon on the afternoon of the crime.
• Denial of Culpability: Petitioner denied having wounded the deceased and denied having confessed his guilt to the witnesses Bagabay, Dumlao, and Llaguno.
• Qualification of the Crime: Petitioner contended that even if he inflicted the wound, he should be convicted only of serious physical injuries rather than homicide, because the wound was not necessarily fatal and the deceased would have survived had he not twice removed the drainage tube placed by the attending physician.

• Identity of the Assailant: Whether the evidence sufficiently established that Juan Quianzon was the person who wounded Andres Aribuabo.
• Qualification of the Crime: Whether the crime is homicide or only serious physical injuries, given the defense's contention that the wound was not necessarily fatal and that the victim's removal of the drainage tube was the real cause of death.
• Proper Penalty: Whether the penalty imposed by the lower court should be modified in light of mitigating circumstances.

• Identity of the Assailant: Yes. The testimony of three disinterested witnesses—Bagabay, Dumlao, and Llaguno—together with the victim's statements as part of the res gestae and the accused's extrajudicial confession, sufficiently established Quianzon as the author of the wound.
• Qualification of the Crime: Homicide. The wound inflicted by the accused was the proximate cause of death; the victim's removal of the drainage tube was an involuntary act done in a paroxysm of pain caused by the wound and did not constitute an independent intervening cause.
• Proper Penalty: Modified. The penalty was reduced to an indeterminate sentence of four years of prision correccional (minimum) to eight years of prision mayor (maximum), in light of the mitigating circumstances of lack of instruction and lack of intention to commit so grave a wrong, with no aggravating circumstances.

• Identity of the Assailant: The Court first discharged the testimony of Simeon Cacpal as improbable, incongruent, and contradictory, agreeing with the defense on this point. Having done so, the defense could not then invoke Cacpal's testimony to discredit the other prosecution witnesses, for if Cacpal was a false witness, none of his statements could be taken into account. The remaining evidence consisted of: (1) the victim's statement immediately after receiving the wound, naming the accused as the aggressor, and the accused's contemporaneous admission that he had applied a firebrand and wounded Aribuabo with a bamboo spit—both admissible as part of the res gestae under sections 279 and 298, No. 7, of the Code of Civil Procedure; and (2) the extrajudicial confession of the accused to barrio lieutenant Dumlao and chief of police Llaguno on the same afternoon. The disinterestedness of these three witnesses was not questioned; no corrupt or wicked motive was imputed to them. Bagabay was not even a relative of the deceased, Dumlao was the accused's own nephew, and Llaguno acted in the performance of official duty. The accused's bare denial could not prevail against their testimony, especially since the defense never suggested that another person might have inflicted the wound, and it was admitted that the accused had attacked the victim with a firebrand before the victim appeared wounded in the abdomen.

• Qualification of the Crime: The Court rejected the defense's contention that the crime was only serious physical injuries. The physician testified that the wound was a penetrating abdominal injury that perforated the large intestine, causing infection from fecal matter and traumatic peritonitis. While the physician admitted the patient might have survived had he not removed the drainage, this did not mean the patient's act was the real cause of death. The wound contributed mediately or immediately to the death, and the fact that other causes cooperated did not relieve the actor of responsibility. The victim's removal of the drainage was not a voluntary act done with knowledge of its prejudicial effect; self-preservation being the strongest instinct, the victim must be assumed to have acted unconsciously due to his pathological condition, nervousness, and the horrible pain caused by the wound and aggravated by contact of the drainage tube with the inflamed peritoneum. The Court cited the Supreme Court of Spain's decision of April 3, 1879, and People vs. Almonte (56 Phil. 54), where a victim died of secondary hemorrhage after moving about against medical advice due to nervousness caused by the wound; in that case the crime was held to be homicide, not slight physical injuries. The principle, drawn from 13 R.C.L. 748 and 751, is that every person is responsible for the natural consequences of his own acts; if a person inflicts a wound with a deadly weapon and death follows, it does not diminish criminality that other causes cooperated in the fatal result.

• Proper Penalty: The Court recognized two mitigating circumstances in favor of the appellant—lack of instruction and lack of intention to commit so grave a wrong as that committed—with no aggravating circumstances. Accordingly, the indeterminate penalty was modified to a minimum of four years of prision correccional and a maximum of eight years of prision mayor.

• Proximate Cause in Homicide — One who inflicts an injury on another is deemed guilty of homicide if the injury contributes mediately or immediately to the death of the victim. The fact that other causes cooperate in producing death does not relieve the actor of responsibility. The principle rests on the foundation that every person is responsible for the natural consequences of his own acts; if death follows from a felonious wound, the criminality is not diminished by proof that other causes, including the victim's own conduct, cooperated in the fatal result. A contrary doctrine would tend to give immunity to crime and remove a salutary safeguard of human life.

• Res Gestae — Statements made by the victim immediately after receiving a wound, naming the assailant, and the contemporaneous admission of the accused, are admissible as part of the res gestae under the Code of Civil Procedure (sections 279 and 298, No. 7).

• Extrajudicial Confession — An extrajudicial confession, if strongly corroborated and shown to have been made freely and voluntarily, constitutes competent evidence against the accused relative to his liability as author of the crime charged.

• Impeachment of a Witness and Its Effect on Co-Witnesses — Where a party successfully impeaches a witness as false, none of that witness's statements may be taken into account or used to influence the consideration of other evidence in the case; the party cannot invoke the impeached witness's testimony to discredit other witnesses.

• "One who inflicts an injury on another is deemed by the law to be guilty of homicide if the injury contributes mediately or immediately to the death of such other. The fact that the other causes contribute to the death does not relieve the actor of responsibility." — This passage states the ratio decidendi on proximate cause: the accused remains liable for homicide when his wound is a cause of death, even if other causes cooperated.

• "While the courts may have vacilated from time to time it may be taken to be settled rule of the common law that on who inflicts an injury on another will be held responsible for his death, although it may appear that the deceased might have recovered if he had taken proper care of himself, or submitted to a surgical operation, or that unskilled or improper treatment aggravated the wound and contributed to the death, or that death was immediately caused by a surgical operation rendered necessary by the condition of the wound." — This quotation from 13 R.C.L. 751, adopted by the Court, articulates the canonical formulation of the doctrine that an assailant is responsible for the natural consequences of his criminal act, including negligent or improper medical treatment of the wound.

• "If Cacpal is a false witness — and the court believes this claim of the defense as true —, none of his statements may be taken into account or should exert any influence in the consideration of the other evidence in the case." — This passage defines the rule that a party who successfully impeaches a witness cannot then selectively rely on that witness's testimony to discredit other witnesses.

• U.S. vs. Macuti, 26 Phil. 170 — Cited as authority for the admissibility of statements as part of the res gestae.
• People vs. Portento and Portento, 48 Phil. 971 — Cited as authority for the admissibility of statements as part of the res gestae.
• U.S. vs. So Fo, 23 Phil. 379 — Cited as authority for the proposition that a voluntary and corroborated extrajudicial confession is evidence against the accused.
• People vs. Cabrera, 43 Phil. 64 — Cited as authority for the evidentiary value of extrajudicial confessions.
• People vs. Almonte, 56 Phil. 54 — Controlling precedent on proximate cause. The victim died of secondary hemorrhage after moving about against medical advice due to nervousness caused by the wound; the Court held the crime was homicide, not slight physical injuries, because the victim's conduct was a natural consequence of the wound inflicted by the assailant. The present case followed Almonte in rejecting the defense that the victim's own conduct broke the chain of causation.

• Sections 279 and 298, No. 7, Code of Civil Procedure — Cited as the statutory basis for admitting the victim's statements and the accused's contemporaneous admissions as part of the res gestae.
• Revised Penal Code (implied) — The penalties of prision correccional, prision mayor, and reclusion temporal, and the mitigating circumstances of lack of instruction and lack of intention to commit so grave a wrong, were applied in modifying the indeterminate sentence.

Avanceña, C.J., Abad Santos, Hull, and Vickers, JJ., concurred.