Urbano Vs Iac
Urbano Vs Iac
Urbano Vs Iac
IAC 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
Facts: 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
On October 23, 1980, petitioner Filomeno Urbano was on his way to his ricefield. He found
possibility that the infection of the wound by tetanus was an efficient intervening cause later
the place where he stored palay flooded with water coming from the irrigation canal. Urbano
or between the time Javier was wounded to the time of his death. The infection was,
went to the elevated portion to see what happened, and there he saw Marcelino Javier and
therefore, distinct and foreign to the crime.
Emilio Efre cutting grass. Javier admitted that he was the one who opened the canal. A
quarrel ensued, and Urbano hit Javier on the right palm with his bolo, and again on the leg There is a likelihood that the wound was but the remote cause and its subsequent infection,
with the back of the bolo. On October 27, 1980, Urbano and Javier had an amicable for failure to take necessary precautions, with tetanus may have been the proximate cause
settlement. Urbano paid P700 for the medical expenses of Javier. On November 14, 1980, of Javier's death with which the petitioner had nothing to do. "A prior and remote cause
Urbano was rushed to the hospital where he had lockjaw and convulsions. The doctor found cannot be made the be of an action if such remote cause did nothing more than furnish the
the condition to be caused by tetanus toxin which infected the healing wound in his palm. condition or give rise to the occasion by which the injury was made possible, if there
He died the following day. Urbano was charged with homicide and was found guilty both by intervened between such prior or remote cause and the injury a distinct, successive,
the trial court and on appeal by the Court of Appeals. Urbano filed a motion for new trial unrelated, and efficient cause of the injury, even though such injury would not have
based on the affidavit of the Barangay Captain who stated that he saw the deceased happened but for such condition or occasion. If no danger existed in the condition except
catching fish in the shallow irrigation canals on November 5. The motion was denied; hence, because of the independent cause, such condition was not the proximate cause. And if an
this petition. independent negligent act or defective condition sets into operation the instances which
Issue: result in injury because of the prior defective condition, such subsequent act or condition is
the proximate cause."
Whether the wound inflicted by Urbano to Javier was the proximate cause of the latter’s
death
Held:
A satisfactory definition of proximate cause is... "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."And more comprehensively, "the
proximate legal cause is that acting first and producing the injury, either immediately or by
setting other events in motion, all constituting a natural and continuous chain of events,
each having a close causal connection with its immediate predecessor, the final event in the
chain immediately effecting the injury as a natural and probable result of the cause which
first acted, under such circumstances that the person responsible for the first event should,
as an ordinarily prudent and intelligent person, have reasonable ground to expect at the
moment of his act or default that an injury to some person might probably result therefrom."
If 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.