Rafael, Simeon, and Beltran were convicted of murdering Bienvenido. Only Rafael appealed. The Supreme Court found that while Rafael intentionally stabbed Bienvenido causing a slight wound, his death was not a direct, natural, and logical consequence of that wound. There was an efficient intervening cause - the sudden participation of Simeon and Beltran who fatally stabbed Bienvenido after he fell. Rafael was therefore only guilty of slight physical injuries, not murder, and his conviction was modified to a lighter penalty.
Rafael, Simeon, and Beltran were convicted of murdering Bienvenido. Only Rafael appealed. The Supreme Court found that while Rafael intentionally stabbed Bienvenido causing a slight wound, his death was not a direct, natural, and logical consequence of that wound. There was an efficient intervening cause - the sudden participation of Simeon and Beltran who fatally stabbed Bienvenido after he fell. Rafael was therefore only guilty of slight physical injuries, not murder, and his conviction was modified to a lighter penalty.
Rafael, Simeon, and Beltran were convicted of murdering Bienvenido. Only Rafael appealed. The Supreme Court found that while Rafael intentionally stabbed Bienvenido causing a slight wound, his death was not a direct, natural, and logical consequence of that wound. There was an efficient intervening cause - the sudden participation of Simeon and Beltran who fatally stabbed Bienvenido after he fell. Rafael was therefore only guilty of slight physical injuries, not murder, and his conviction was modified to a lighter penalty.
Rafael, Simeon, and Beltran were convicted of murdering Bienvenido. Only Rafael appealed. The Supreme Court found that while Rafael intentionally stabbed Bienvenido causing a slight wound, his death was not a direct, natural, and logical consequence of that wound. There was an efficient intervening cause - the sudden participation of Simeon and Beltran who fatally stabbed Bienvenido after he fell. Rafael was therefore only guilty of slight physical injuries, not murder, and his conviction was modified to a lighter penalty.
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People v. Marco 5.
On the theory that there was obvious conspiracy among appellants
G.R. No. L- 28324-5 Rafael, Simoen, and Beltran, the trial court convicted them of murder. May 19, 1978 | Barredo, J. | Criminal liability – Wrongful act different from that Only Rafael appealed. intended; efficient intervening cause ISSUE: PETITIONER: People of the Philippines 1. WON Rafael can be held liable for the death of Bienvenido under RESPONDENTS: Rafael Marco, Simeon Marco and Dulcisimo Beltran Art. 4, par. 1 of the RPC. NO. DOCTRINE: Art. 4, par. 1 of the RPC: Criminal liability — Criminal liability shall be incurred: RATIO: (1) By any person committing a felony (delito) although the wrongful act 1. Under Art. 4, par. 1 of the RPC, one who commits an intentional felony done be different from that which he intended. is responsible for all the consequences which may naturally and logically Efficient intervening cause – it is the cause w/c interrupted the natural flow of result therefrom, whether foreseen or intended or not. the events leading to one’s death. This may relieve the offender from liability. 2. Tthe stabbing of the Bienvenido by Rafael which caused a slight wound on the Bienvenido's hand was intentionally made; hence, felony. FACTS: However, the ensuing death of Bienvenido was not the direct, natural, and logical consequence of the wound inflicted by the Rafael. 1. Simeon, son of Rafael, approached Constancio and after asking him if he 3. There was an active intervening cause, which was no other than the were the one who boxed his (Simeon's) brother the year before, sudden and unexpected appearance and participation of Simeon Marco brandished a hunting knife, which caused Constancio to run away. and Dulcisimo Beltran. And there is authority that if the consequences 2. While Constancio was running, he passed by Rafael who hit him with a produced have resulted from a distinct act or fact absolutely foreign from cane causing him slight physical injuries. When Simeon was about to the criminal act, the offender is not responsible for such consequence. pursue Constancio, the latter's father, Vicente, who was in the crowd, 4. Therefore, there was no clear evidence connecting the act of Rafael in grabbed Simeon's hand that was holding the knife. trying to stab the Bienvenido which caused the latter injuries on the left 3. When Vicente, however, saw that Rafael, who was holding a round cane hand, with the fatal stabs inflicted by his two other co-accused. and a hunting knife, was approaching them, he shouted to Constancio and to his other son Bienvenido who appeared in the scene to run away, DISPOSITIVE PORTION: which they did, as he himself released Simeon and ran away. 4. Rafael followed Bienvenido and stabbed him, but the latter parried the IN VIEW OF ALL THE FOREGOING, the decision appealed from is hereby blow which caused injuries to his left hand. Bienvenido tried to run modified, and in its stead appellant is found guilty only of slight physical injuries farther but his feet got entangled with some vines and he fell down. and hereby sentenced to suffer the penalty of twenty (20) days of arresto menor, Whereupon, Beltran, who came from nowhere, stabbed him near the and to pay the costs. anus, followed by Simeon who stabbed him on the left side of the breast. Thereafter, Bienvenido died.