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People v.

Iligan
Under factors affecting intent and the offender’s criminal liability, proximate cause.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. FERNANDO ILIGAN y JAMITO, EDMUNDO
ASIS y ILIGAN and JUAN MACANDOG (at large), Defendants, FERNANDO ILIGAN y JAMITO and
EDMUNDO ASIS y ILIGAN, Defendants-Appellants.
Facts:

Fernando Iligan, his nephew Edmundo Asis, and Juan Macandog met Esmeraldo Quiñones, Jr. and his
companions Zaldy Asis and Felix Lukban by a ricemill as the latter walked from a barrio fiesta. Edmundo
Asis instigated a fight by pushing Zaldy Asis who boxed him thereafter. Felix Lukban told the party of
Iligan that they didn't want to fight yet when Asis fell, Iligan drew his bolo missing a strike to Asis' head.

The party of Quinoñes passing by his house, he after a while asked his companions to walk back with
him so could change for work as a bus conductor.

Upon arrival with no word, Iligan stroke his bolo to Quinoñes' head causing him to fall, this made Lukban
and Asis flee to a distance of 200m and later walked back as they heard shouts "may nadale na."

There layed the corpse of Quinoñes which they lifted into the house.

the autopsy showed a fracture on the left side of the victim's head, showing a distinct cut, as well as a
short one by his eyebrow and bruises by his neck and shoulders.
with conclusion of death due "shock and massive cerebral hemorrhages due to a vehicular accident."

the RTC ruled Iligan guilty of murder, Asis guilty of conspiracy to which they appealed to the CA seeking
reversal contending the death was caused by vehicular accident.

Issues:

whether the accused can be acquitted from the criminal liability of the victim's death.

no, despite the fact that the vehicular accident was the final cause of death of Quiñones, it was Iligan's
hacking of the victim's head that caused the latter's death.

proximate cause is defined as "that acting first and producing the injury either immediately or by setting
other events in motion which causes the final injury to which such events has closely causal relation
and the perpetrator has intelligence/reasonable ground to expect that the final event shall result
therefrom his initiated offense/injury.

it was the weapon of use, a bolo, and the target from the victim's body; the head which proved that
the accused had intent not only to immobilize the victim, but to kill. Whereas in conclusion, even though
the blow from the bolo did not kill the victim, it led him to his death as he fell from the ground thereafter
was presumed to be hit by a vehicle.

2. whether Asis can be acquited from conspiring to the death of the victim.

yes, merely appearing at the crime scene does not provide sufficient proof for conviction of conspiracy
as it requires actual and intentional involvement/contribution to its success.
People v. Iligan
Under factors affecting intent and the offender’s criminal liability, proximate cause.

No corroborated testimony gave proof that Asis conspired to the death of Quiñones, only one from the
father of the victim which the court deemed bias.

requisites of proximate cause and conspiracy were expressed from former resolved cases;
http://www.chanrobles.com/cralaw/1990novemberdecisions.php?id=2138

Ruling:

Appellant Fernando Iligan y Jamito was convicted of the crime of homicide for which he is imposed the
indeterminate penalty of six (6) years and one (1) day of prision mayor as minimum to fourteen (14)
years, eight (8) months and one (1) day of reclusion temporal medium as maximum and he shall
indemnify the heirs of Esmeraldo Quiñones, Jr. in the amount of fifty thousand pesos (P50,000).
Appellant Edmundo Asis was acquitted due to lack of merit. Costs against appellant Iligan.

From murder conviction by the RTC against Iligan to homicide after failing to prove aggravating
circumstance of premeditation and treachery.

premeditation requires an orchestrated date for the murder, to which the same shall be proven in court
to have had determination to execute, and a duration between the plan and commission for the
perpetrator to have contemplation in pursuing or not.

full text:
(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 him to reflect upon the consequences of his
act. (People v. Batas, G.R. Nos. 84277-78, August 2, 1989, 176 SCRA 46).

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