People vs. Reyes

An offender is liable for homicide where his criminal assault is the proximate cause of death, even if the wound inflicted was superficial and death resulted from shock. Liability follows because the accused must answer for the consequences of his wrongful act, and one who stabs another on a vital part of the body with a lethal weapon is presumed to have intended the natural consequences of the act.

Gregorio Reyes and Fausta Tavera had been living together for a couple of weeks before the killing. Tavera had returned to her parents upon their persuasion, and her parents were demanding that Reyes pay a dowry of P30 before the date for celebration of the marriage could be fixed. No other statutory or institutional backdrop is detailed in the decision beyond the criminal prosecution that followed.

Previous to the killing, Fausta Tavera had for a couple of weeks been living with Gregorio Reyes, but her parents had persuaded her to come home and were demanding that Reyes pay a dowry of P30 before the date of the celebration of the marriage could be fixed. On the evening of April 30, 1934, after a barrio procession, persons were gathered in one of the houses where an impromptu dance took place.

Reyes and Tavera were talking in the yard of the house where the dance was taking place, and she informed him that she could not return to him and that she was going with her parents to Catanduanes. Reyes then dragged Tavera towards the street and stabbed her in the chest with a fanknife. Tavera ran screaming to the house of the barrio lieutenant a short distance away, falling dead at the foot of the staircase, although the wound was only slight, not having penetrated the thoracic cavity after hitting a bone.

Immediately thereafter, Andres Tapil, Tomas and Rufino, relatives of the deceased, attempted to seize Reyes, but with the aid of his knife he escaped and ran from the scene of the affray. According to Reyes, testifying as a witness in his own behalf, he was attacked by the three relatives of the deceased, and if the deceased was wounded by him, it was in the midst of that affray and purely accidental on his part.

The sanitary inspector who examined the body the next day found no other wound and certified that the deceased had died from shock as a result of the wound, so testifying at the trial. The death having occurred in an outlying barrio, there was no proper autopsy, and so far as known the deceased was in normal health. The trial court did not believe Reyes's version, a finding noted to have been greatly weakened by his own statement given to the chief of police the day after the crime.

• Nature of wound and liability for homicide: Appellant contended that he cannot be convicted of homicide as the wound actually inflicted was a superficial wound of no intrinsic magnitude.
• Cause of death and burden of proof: Appellant contended that it was incumbent upon the State to prove that the deceased did not die of poisoning or some other cause.
• Accidental wounding in affray: Appellant claimed that he was attacked by the three relatives of the deceased, and that if the deceased was wounded by him, it was in the midst of that affray and purely accidental on his part.

• Causation and liability for homicide: Whether appellant may be convicted of homicide where the stab wound was superficial and death was certified as due to shock resulting from the wound.
• Proof of other causes of death: Whether the State was required to prove that the deceased did not die of poisoning or some other cause.
• Mitigating circumstances: Whether the mitigating circumstances of lack of intention to commit so grave a wrong and sufficient provocation on the part of the offended party attended the commission of the crime.

• Causation and liability for homicide: Yes. Liability for homicide was sustained because the stabbing was the proximate cause of death by shock, for which the offender must answer.
• Proof of other causes of death: No. The State was not required to disprove poisoning or another cause where the assault was shown to be the proximate cause of death.
• Mitigating circumstances: No. Neither lack of grave intent nor provocation attended the crime, the means employed contradicting lack of intent and the alleged provocation not having come from the deceased.

• Causation and liability for homicide: The deceased, in normal health so far as known, ran screaming a short distance and dropped dead after being stabbed in the chest, with no other wound found and death certified as shock resulting from the wound. Because the assault was the proximate cause of death, responsibility attached even though the wound was slight and did not penetrate the thoracic cavity, pursuant to settled jurisprudence that a person answers for the consequences of his criminal act.
• Proof of other causes of death: No autopsy was available because death occurred in an outlying barrio, but the absence of another wound and the certification of death from shock sufficed to link death to the stabbing. The contention that the State must affirmatively exclude poisoning or other causes was rejected as contrary to settled law, especially where no diseased condition or alternative cause was shown.
• Mitigating circumstances: The means employed — stabbing the chest with a fanknife, a lethal weapon upon a vital part where death could reasonably be anticipated — raised the presumption that the accused intended the natural consequences of the wrongful act and contradicted lack of intention to commit so grave a wrong. Provocation was also absent because the law requires provocation from the offended party, yet the deceased did not attack appellant and her refusal to renew the illicit relationship could hardly be construed as legal provocation.

• Responsibility for proximate consequences of criminal act — A person is responsible for the consequences of his criminal act where that act is the proximate cause of death, even if the deceased was in a diseased condition or the wound was not intrinsically mortal. The doctrine was applied to hold Reyes liable for homicide where a slight chest wound produced fatal shock, the stabbing being the proximate cause.
• Presumed intent from use of lethal weapon on vital part — When a person stabs another with a lethal weapon such as a fanknife upon the head, chest, or stomach, death could reasonably be anticipated and the accused must be presumed to have intended the natural consequences of the wrongful act. The doctrine was applied to reject the mitigating circumstance of lack of intention to commit so grave a wrong.
• Provocation as mitigating circumstance must come from the offended party — Sufficient provocation or threat immediately preceding the act mitigates only when it originates with the victim. The doctrine was applied to reject provocation where the deceased merely refused to renew the illicit relationship and did not attack appellant.

• "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), appellant's assault being the proximate cause of the death, he would be responsible" — States the controlling causation rule sustaining homicide liability despite the superficial character of the wound.
• "We have repeatedly held that when a person stabs another with a lethal weapon such as a fanknife upon a part of the body, for example, the head, chest, or stomach, death could reasonably be anticipated, and the accused must be presumed to have intended the natural consequences of his wrongful act." — Supplies the canonical formulation rejecting lack of grave intent where a vital part is stabbed with a lethal weapon.
• "Certainly the deceased did not attack appellant, and her refusal to renew her illicit relationship with him can hardly be construed as legal provocation." — Defines why provocation was absent, emphasizing that qualifying provocation must come from the offended party.

• U.S. vs. Luciano, 2 Phil., 96 — Cited as settled authority that the offender answers where his assault is the proximate cause of death.
• U.S. vs. Lugo and Lugo, 8 Phil., 80 — Cited as settled authority supporting proximate-cause responsibility for the consequences of a criminal act.
• U.S. vs. Brobst, 14 Phil., 310 — Cited as settled authority supporting proximate-cause responsibility for the consequences of a criminal act.
• U.S. vs. Rodriguez, 23 Phil., 22 — Cited as settled authority supporting proximate-cause responsibility for the consequences of a criminal act.

• Act No. 4103 — Applied to impose the indeterminate sentence of from eight years of prision mayor to fourteen years, eight months, and one day of reclusion temporal for homicide without aggravating or mitigating circumstances.

Avanceña, C.J., Malcolm, Vickers, Imperial, Butte, Goddard, and Diaz, JJ., concur.

• Abad Santos, J. — Maintained that appellant should be acquitted, being inclined to believe that appellant was attacked by the three men with the deceased and that the deceased was accidentally wounded in the ensuing fight. Emphasized that the examining physician described the wound as merely a scratch of a nature that ordinarily would not have resulted in death, and did not believe appellant had intended to commit homicide.