January 7, 1988
FACTS:
On October 23, 1980, petitioner Filomeno Urbano went to his ricefield and found the place where he stored his palay flooded with water coming from the irrigation canal nearby which had overflowed. Urbano saw Javier and the latter admitted that he was the one responsible. A quarrel between them ensued. Urbano unsheathed his bolo hacked Javier hitting him on the right palm of his hand, which was used in parrying the bolo hack. Urban was also hacked Javier on the left leg with the back portion of said bolo, causing a swelling on said leg.
Upon the intercession of Councilman, Urbano and Javier agreed to settle their differences. Urbano promised to pay P700.00 for the medical expenses of Javier. Hence, on October 27, 1980, the two accompanied by Solis appeared before the San Fabian Police to formalize their amicable settlement.
However, on November 14, 1980, Javier was rushed to the hospital with a lockjaw and was having convulsions. The doctor found that it was caused by tetanus toxin. He noticed the presence of a healing wound in Javier's palm which could have been infected by tetanus.
On November 15, 1980 Javier died in the hospital. An information for homicide was filed against Urbano. The RTC found Urbano guilty of the crime charged.
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 (YES)
HELD:
The evidence on record does not clearly show that the wound inflicted by Urbano was infected with tetanus at the time of the infliction of the wound.
We look into the nature of tetanus-
The incubation period of tetanus, i.e., the time between injury and the appearance of unmistakable symptoms, ranges from 2 to 56 days. However, over 80 percent of patients become symptomatic within 14 days. A short incubation period indicates severe disease, and when symptoms occur within 2 or 3 days of injury the mortality rate approaches 100 percent.
Therefore, medically speaking, the reaction to tetanus found inside a man's body depends on the incubation period of the disease.
In the case at bar, Javier suffered a 2-inch incised wound on his right palm when he parried the bolo which Urbano used in hacking him. This incident took place on October 23, 1980. After 22 days, or on November 14, 1980, he suffered the symptoms of tetanus, like lockjaw and muscle spasms. The following day, November 15, 1980, he died.
If, therefore, the wound of Javier inflicted by the appellant was already infected by tetanus germs at the time, it is more medically probable that Javier should have been infected with only a mild cause of tetanus because the symptoms of tetanus appeared on the 22nd day after the hacking incident or more than 14 days after the infliction of the wound. Therefore, the onset time should have been more than six days. Javier, however, died on the second day from the onset time. The 
more credible conclusion is that at the time Javier's wound was inflicted by the appellant, the severe form of tetanus that killed him was not yet present. Consequently, Javier's wound could have been infected with tetanus after the hacking incident. Considering the circumstance surrounding Javier's death, his wound could have been infected by tetanus 2 or 3 or a few but not 20 to 22 days before he died.
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.
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