Criminal Law

People v. Ulep G.R. No. L-36858 June 20, 1988 Criminal Liability, Proximate Cause

FACTS:

On May 21, 1970, at nine o’clock in the evening, Asuncion Pablo Ulep died as a result of physical injuries inflicted upon her by her husband, accused Macario Ulep. 

The following day, the Chief of Police received a report of the said death of Asuncion who allegedly died of a heart attack. 

The Chief of Police suggested that an autopsy be conducted but the husband refused to allow the same. However, the daughter of the deceased by a previous marriage demanded for an autopsy. 


During the investigation, the accused admitted that he caused the death of his wife by elbowing her because his wife was then drunk and was uttering indecent words.

Ulep, however, retracted his statement in court by narrating that when his wife went to have their palay milled, a bullcart loaded with sacks of rice turned upside down and pinned his wife on her breast .

The RTC convicted Ulep of the crime of parricide.

ISSUE:

Whether or not the accused is liable for the death of his wife.

RULING:

We have previously stated that:

Even if the victim is suffering from an internal ailment, liver or heart disease, or tuberculosis, if the blow delivered by the accused —

(a) is the efficient cause of death; or

(b) accelerated his death; or

(c) is the proximate cause of death; 

then there is criminal liability. 

Apropos to all these is that time-respected doctrine: “He who is the cause of the cause is the cause of the evil caused.” This is the rationale in Article 4 of the Revised Penal Code which provides that “criminal liability shall be incurred by a person committing a felony (delito) although the wrongful act done be different from that which he intended.”

Again, We elucidated that: even though a blow with the fist or a kick does not cause any external wound, it may easily produce inflammation of the spleen and peritonitis and cause death, and even though the victim may have been previously affected by some internal malady, yet if the blow with the fist or foot accelerated death, he who caused such acceleration is responsible for the death as the result of an injury willfully and unlawfully inflicted. 

We are, therefore, convinced that there is no fundamental disagreement between the two medical witnesses as to the cause of the victim’s death and that cardiac arrest and primary shock took away the life of the victim, Asuncion Pablo.

There is that clear and categorical showing that on the appellant fell the blame for these in human acts on his wife. He should answer for her tragic death.

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