PEOPLE vs. VILLACORTA

G.R. No. 186412

September 7, 2011

FACTS: 

While Cruz was ordering bread at Mendeja’s store, Villacorta suddenly appeared and stabbed Cruz on the left side of Cruz’s body using a sharpened bamboo stick. The bamboo stick broke and was left in Cruz’s body. Immediately after the stabbing incident, Villacorta fled. 

RTC rendered a Decision finding Villacorta guilty of murder, qualified by treachery. The Court of Appeals promulgated its Decision affirming in toto the RTC judgment of conviction against Villacorta. 

ISSUE: 

Whether or not there was an efficient intervening cause from the time Javier was wounded until his death which would exculpate Urbano from any liability for Javier's death 

HELD:

The proximate cause of Cruz’s death is the tetanus infection and not the stab wound.

In the event he is found to have indeed stabbed Cruz, he should only be held liable for slight physical injuries for the stab wound he inflicted upon Cruz.

If Cruz acquired severe tetanus infection from the stabbing, then the symptoms would have appeared a lot sooner than 22 days later. Ultimately, we can only deduce that Cruz’s stab wound was merely the remote cause, and its subsequent infection with tetanus might have been the proximate cause of Cruz's death. The infection of Cruz’s stab wound by tetanus was an efficient intervening cause later or between the time Cruz was stabbed to the time of his death.  The rule is that the death of the victim must be the direct, natural, and logical consequence of the wounds inflicted upon him by the accused. And since we are dealing with a criminal conviction, the proof that the accused caused the victim's death must convince a rational mind beyond reasonable doubt. The medical findings, however, lead us to a distinct possibility that the infection of the wound by tetanus was an efficient intervening cause later or between the time Javier was wounded to the time of his death. The infection was, therefore, distinct and foreign to the crime.  *The above case digest is only a guide. I highly suggest that you read the FULL TEXT.