People vs. Ulep

The Court held that an accused is criminally liable for parricide when the blows he inflicts upon his spouse are the efficient, accelerating, or proximate cause of death, even if the victim had a pre-existing internal ailment. The governing principle is that "he who is the cause of the cause is the cause of the evil caused," pursuant to Article 4 of the Revised Penal Code.

Macario A. Ulep and Asuncion Pablo Ulep were spouses residing in San Nicolas, Ilocos Norte. On the evening of May 21, 1970, Asuncion died after her husband inflicted physical injuries upon her. The accused initially refused an autopsy but later admitted in two sworn statements that he had elbowed his wife multiple times on the breast during an argument. The autopsy revealed multiple rib fractures, and the cause of death was determined to be cardiac arrest and primary shock. The accused was charged with parricide.

• On May 21, 1970, at approximately 9:00 P.M., Asuncion Pablo Ulep died in her home in San Nicolas, Ilocos Norte.
• The Chief of Police received a report that she died of a heart attack. The accused, her husband Macario Ulep, initially refused an autopsy.
• At the request of the victim's daughter from a previous marriage, an autopsy was conducted at the cemetery shortly before burial by Dr. Eliseo Bonoan.
• The autopsy report listed the cause of death as "CARDIAC ARREST PRIMARY SHOCK," noting multiple rib fractures and the presence of serous fluid in the thoracic and abdominal cavities.
• Two weeks after the burial, the accused executed two sworn statements (Exhibits "A" and "B") before a fiscal, admitting that he had caused his wife's death by elbowing her on the breast because she was drunk and uttering indecent words.
• At trial, the accused retracted his statements, claiming his wife had sustained chest injuries over a year earlier when a bullcart loaded with sacks of rice overturned and pinned her.
• The defense presented Dr. Pedro Blanco, who testified that the victim's death resulted from a long-standing bodily condition, not the recent elbow blows.

• The People, through the Solicitor General, argued that the accused's extrajudicial confessions were voluntary and credible, establishing that he inflicted the fatal injuries.
• The prosecution contended that the autopsy findings, particularly the multiple rib fractures, were consistent with the accused's admission of elbowing the victim and were the proximate cause of the cardiac arrest and primary shock that led to her death.
• It maintained that any pre-existing condition was irrelevant because the accused's unlawful acts were the efficient cause of death.

• The accused-appellant argued that the trial court erred in relying on his extrajudicial admissions, which he claimed were mere beliefs, not factual admissions of causation.
• He contended that the cause of death was a long-standing internal condition, as suggested by the presence of serous fluid in the abdominal cavity and the absence of external chest contusions, which indicated the fractures were old.
• The defense asserted that the elbow blows lacked sufficient force to cause the fractures and that the fractures themselves were not depressed and could not have injured the heart to cause cardiac arrest.

• Procedural Issues: N/A
• Substantive Issues:
  • Whether the cause of death of Asuncion Pablo Ulep was the elbow blows inflicted by the accused-appellant.
  • Whether the accused-appellant is criminally liable for parricide despite the alleged pre-existing medical condition of the victim.

• Procedural: N/A
• Substantive: The Court ruled against the accused-appellant. It found that the prosecution proved beyond reasonable doubt that the accused's elbow blows were the proximate cause of his wife's death. The Court gave credence to the autopsy report by Dr. Bonoan and the accused's own extrajudicial confessions. It rejected the defense's theory of a pre-existing condition, finding no credible evidence that such condition, rather than the inflicted trauma, caused the cardiac arrest. The Court applied the principle that an assailant is liable even if he only accelerated the death of a person already suffering from an illness.

• "He who is the cause of the cause is the cause of the evil caused." — This principle, embodied in Article 4 of the Revised Penal Code, establishes that criminal liability is incurred for a felony even if the wrongful act done is different from that intended. The Court applied it to hold the accused liable for death resulting from the injuries he intentionally inflicted.
• Proximate Cause in Homicide with Pre-existing Condition — The Court reiterated the doctrine that even if the victim had an internal ailment, the accused is criminally liable if the blow he delivered was the efficient cause of death, accelerated death, or was the proximate cause of death.

• "A man must love his wife. He must not lift a finger to hurt her. Indeed he must be her protector. When against this unwritten rule he beats her, he ceases to be a man. He becomes a beast. And the law imposes the supreme penalty when in the process he kills her. It is parricide pure and simple." — This passage frames the moral and legal gravity of the crime of parricide within the marital relationship.
• "Even if the victim is suffering from an internal ailment, liver or heart disease, or tuberculosis, if the blow delivered by the accused — (a) is the efficient cause of death; or (b) accelerated his death; or (c) is the proximate cause of death; then there is criminal liability." — This quote succinctly states the controlling legal rule applied by the Court regarding causation.

• People v. Ilustre, 54 Phil. 594 — Cited for the proposition that criminal liability exists for death resulting from a blow even if the victim had a pre-existing internal ailment, if the blow was the efficient or accelerating cause.
• United States v. Rosalinda Rodriguez, 23 Phil. 22 — Cited to support the principle that a person who unlawfully accelerates another's death is responsible for that death, even if the victim was previously ill.

• Article 4 of the Revised Penal Code — Provides that criminal liability shall be incurred by a person committing a felony although the wrongful act done be different from that which he intended. The Court invoked this to support the "cause of the cause" doctrine.
• Wharton & Stille's Medical Jurisprudence, 5th Ed., Sec. 225 on "Shock" — The Court referenced this treatise to support the medical possibility of death from shock associated with an injury, even where the injury leaves no significant external trace.