Criminal Law

PEOPLE v. VILLACORTA G.R. No. 186412 September 7, 2011 Proximate Cause, Efficient Intervening Cause, Slight Physical Injuries


Witness Cristina Mendeja narrated that on January 23, 2002, at around 2:00AM, when Danilo Cruz was buying bread, Orlito Villacorta suddenly appeared and, without uttering a word, stabbed Cruz, using a sharpened bamboo stick. The bamboo stick broke and was left in Cruz’s body. Villacorta immediately fled thereafter. Her neighbor Aron removed the broken bamboo stick from Cruz’s body.

Mendeja and Aron then brought Cruz to Tondo Medical Center.

According to Dr. Belandres’ findings, Cruz sustained a stab wound, and was treated as an out-patient that day. Cruz was once again brought to the San Lazaro Hospital on February 14, 2002, where he died the following day. 

Dr. Belandres was able to determine that Cruz died of tetanus infection secondary to stab wound. 

The RTC rendered a Decision finding Villacorta guilty of murder, qualified by treachery. 

On appeal, the CA Affirmed in toto the RTC judgment.

Hence, this instant appeal.


Whether or not there was an efficient intervening cause from the time Cruz was wounded until his death which would exculpate Villacorta from any liability for Cruz’s death.


There is merit in the argument proffered by Villacorta that 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. The proximate cause of Cruz’s death is the tetanus infection, and not the stab wound.

Proximate cause has been defined as “that cause, which, in natural and continuous sequence, unbroken by any efficient intervening cause, produces the injury, and without which the result would not have occurred.”

We quote from the ratiocination of the Court in Urbano v. Intermediate Appellate Court:

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. 

We face similar doubts in the instant case that compel us to set aside the conviction of Villacorta for murder. There had been an interval of 22 days between the date of the stabbing and the date when Cruz was rushed to San Lazaro Hospital, exhibiting symptoms of severe tetanus infection. If Cruz acquired severe tetanus infection from the stabbing, then the symptoms would have appeared a lot sooner than 22 days later. 

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.

However, Villacorta is not totally without criminal liability. Villacorta is guilty of slight physical injuries under Article 266(1) of the RTC for the stab wound he inflicted upon Cruz. Although the charge in the instant case is for murder, a finding of guilt for the lesser offense of slight physical injuries may be made considering that the latter offense is necessarily included in the former since the essential ingredients of slight physical injuries constitute and form part of those constituting the offense of murder. 

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