Art. 4. Criminal liability.

Criminal liability shall be incurred: (1) By any person committing a felony

(delicto) although the wrongful act done be different from that which he intended. El que es causa de la
causaes causa del mal causado (he who is the cause of the cause is the cause of the evil caused) To be
criminally liable for a felony different that which he intended: 1) An intentional felony has been
committed 2) Wrong done to the aggrieved party be the direct, natural and logical consequence of the
felony committed (wrong done is the proximate cause of the felony) Proximate cause: (close casual
connection of the immediate predecessor) a. initial act is a felony b. cause is a felony itself c. natural or
probable cause d. there is no supervening, sufficient intervening cause Standard = expectation of an
ordinary, prudent and intelligent person (what is plausible to happen; does not usually require scientific
evidences) The felony committed is not the proximate cause of the resulting injury when: 1) There is an
active force that intervened between the felony committed and the resulting injury, and the active force
is a distinct act or fact absolutely foreign from the felonious act of the accused; or 2) The resulting injury
is due to the intentional acts of the victim People vs. Iligan, November 26, 1990 Facts: August 4, 1980,
2AM The 3 ran for 2 hours passing by Quiones house then they saw that they were no longer
pursued Quiones invited them to accompany him to his house, on their way, the three suddenly
appeared. Ilagan hacked Quiones with the bolo and was hit on his forehead causing him to fall down.
Lukban and Zaldy Asis fled 200 meters returned when they heard shouts of people Dr. Marcelito
Abas: 21 yr old died because of shock and massive cerebral hemorrhages due to a vehicular accident
Defense: he left his house to fetch visitors at the dance hall and met Edmundo Asis (presumed
drunk) along the way, found he was boxed by someone whom he sideswept so Iligan brought him home
instead. Juliano Mendoza, invited by him to cook at his house. After bringing nephew in his house,
came home between 1:30 to 2 AM Issue: Can Iligan be held criminally liable when the cause of
Quiones death was vehicular accident? Held: Yes Ratio: Article 4 paragraph 1 (Result is different
from what is intended is still punishable) proximate cause (close casual connection of the immediate
predecessor) he who is the cause of the cause is the cause of the evil caused.
 Hacking incident happened on the national highway where vehicles are expected to pass any moment
Disposition: Iligan guilty of homicide 6 years, 1 day prision mayor 14 years, 8 months and 1 day
reclusion temporal medium P50,000 indemnity to the heirs. Edmundo Asis acquitted. Costs against
Iligan Facts: People vs. Manaquil, September 28, 1984 March 6, 1965, Pasay City, Valentina Mananquil
killed her husband Elias Day by setting him on fire in NAWASA building where he was working. 11PM
she had just purchased 10 centavo gasoline placed in a coffee bottle, she knocked at the door and Elias
shouted at the apellant and castigated and cursed at her got the bottle and poured on his face and set
his polo shirt on fire March 10 (after 4 days), Elias died due to pneumonia, lobar bilateral burns 2nd
degree Appellants story: bought gasoline to clean her shoes because the day after the incident is a
Sunday also she remembered that her husband needed gasoline for his lighter in NAWASA, husband
was drunk and cursed at her she was dizzy and she did not know that she was already sprinkling gasoline
on husband's face went back to apologize, found police accused her of burning the husband and made
her sign a document in the promise that she'll be freed Pled not guilty, but RTC: reclusion perpetua to
indemnify the heirs of the deceased in the amount of P12,000.00; and to pay costs Mananquil to SC:
(moved to SC because the penalty is reclusion perpetua) 1) whether the extrajudicial confession was
voluntarily given 2) whether the burns sustained caused the victims pneumonia which was the cause of
the victims death Issue: Is her defense that pneumonia is the cause of death valid? Held: No Ratio:
The claim that the victim drank liquor while confined in the hospital would not suffice to exculpate the
appellant. For as testified by Dr. Reyes, pneumonia could not be caused by taking alcohol. The
evidence shows that pneumonia was a mere complication of the burns sustained. While accepting
pneumonia as the immediate cause of death, the court a quo held on to state that this could not litem
resulted had not the victim suffered from second degree burns. Article 4 paragraph 1 Pneumonia
was the immediate cause of death however the burns were the proximate cause of death Proximate
cause here is something a question of expectation or natural consequence (it was expected that burning
someone would hurt a person) One who inflicts injury on another is deemed guilty of homicide if it
contributes mediately or immediately to the death of each other The burning was directly contributory
mediately or immediately to the death of such other Facts: US vs Brobst, October 25, 1909 Mann
discharged Simeon Saldivar from working in the mine because he was a thief and told James Brobst not
to employ him again July 10, 1907 6AM, Saldivar with 3 or 4 went to look for work Brobst was in the tent
ordered him off the place "Begone" twice...Saldivar merely smiled or grinned at him 3 steps forward,
Saldivar, struck him a powerful blow with closed fist on the left side, just over the lower ribs, at the point
where his bolo's handle lay against his belt
Saldivar threw up his hands, staggered and without saying a word, went away in the direction of his
sister's house 200 yards away and about 100 feet up at the side of a hill. Died as he reached the door
and was buried 2-3 days later Trial Court: guilty homicide with extenuating circumstances, 6 years, 1 day
prision mayor Defense: evidence fails to prove that the blow was the cause of death defendant has
perfect right to eject Saldivar, he cannot be held criminally liable for unintentional injuries inflicted in
the lawful exercise of his right. Witnesses Dagapdap and Yotiga: the hard blow was with a closed fist
bofetada - slap w/ an open hand on the cheek puetazo - blow w/ a fist Witness Leocampo: saw the
accused start toward the deceased with his arm outstretched, clenched fist Defendant: stepped up to
him and pushed him lightly with the back of his hand, which came in contact with the bolo Appellant:
death may have been the result of some unknown fall, robbers, suicide; he is entitled to the benefit of
the doubt. Issue: Is Brobst excused from liability? Held: No. Ratio: Art. 4 paragraph 1 Result is
different from what is intended is still punishable Court takes note of the inflicted injury before death
(since there is no more proof that could lead to the death of a person) Dissent: witnesses have
conflicting claims (blow with an open hand or a closed fist? unsupported by evidence, mere
presumption of facts the basis should be that the injury is sufficient to produce death must be
decided in favor of an accused person in a criminal trial is a reasonable doubt, and not a mere whimsical
and fanciful doubt, based upon imagined but wholly improbable possibilities, unsupported by evidence