People of the Philippines vs Orlito Villacorta
657 SCRA 270 – Criminal Law – Criminal Liability – Proximate Cause – Efficient Intervening Cause
On January 22, 2002, Danilo Cruz went to a sari-sari store to buy bread. Out of nowhere, Orlito Villacorta appeared and thereafter stabbed the left part of the body of Cruz with a sharpened bamboo stick. After that, Villacorta fled.
Cruz was helped by bystanders and he was brought to a nearby hospital where he was treated as out-patient. He was discharged on the same day but on February 14, 2002, or 21 days after the stabbing incident, he returned to the same hospital where he was treated for severe tetanus. The next day on February 15, 2002, Cruz died. The medical report states that Cruz died of tetanus infection secondary to stab wound.
The trial court as well as the Court of Appeals convicted Villacorta for murder.
ISSUE: Whether or not Villacorta is guilty of murder.
HELD: No. In this case, the proximate cause of the death is not the stabbing done by Villacorta upon Cruz. There was an efficient intervening cause which appeared between the time of the stabbing and the time of the death of Cruz.
In explaining this, the Supreme Court took into consideration the fact that severe tetanus (the kind of tetanus which causes immediate death) has an incubation period of 14 days or less. In this case, the stabbing made by Vilalcorta could not have caused the tetanus infection as 22 days already lapsed from the time of the stabbing until the date of death of Cruz. Something else caused the tetanus other than the stabbing – in short, Cruz acquired the tetanus 14 days or less before February 15, 2003 and not on the date of stabbing.
The court explained further:
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 [Cruz] was wounded to the time of his death. The infection was, therefore, distinct and foreign to the crime.
Villacorta is however guilty of slight physical injuries based on the facts. Neither is he guilty of attempted nor frustrated murder, his intent to kill was not proven by the prosecution.