G.R. No. L-31335 February 29, 1972
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PABLO RELOJ alias AMBOY, defendant-appellant.

FACTS

On July 7, 1963, Pablo Reloj stabbed Justiniano Isagan Sr. with an ice pick outside a cockpit in Kalibo, Aklan. The victim was rushed to the hospital where a successful operation was performed. However, five days later, he developed paralytic ileus, a known surgical complication, and died. Reloj was charged with and convicted of murder by the Court of First Instance of Aklan, which sentenced him to life imprisonment. The prosecution evidence, deemed credible by the trial court, established that Reloj approached the victim from behind and stabbed him suddenly. Witnesses Justiniano Isagan Jr. and Hermie Zante corroborated this account, and the victim’s ante-mortem declaration was also presented. Additional testimony revealed Reloj had made threats to kill the victim earlier that day.

ISSUE

The core issues on appeal concern the correctness of the conviction for murder, specifically: (1) whether Reloj is criminally liable for the death given the intervening medical complication; (2) whether treachery qualified the killing to murder; and (3) what penalties and mitigating circumstances apply.

RULING

The Supreme Court affirmed the conviction but modified the penalty. On criminal liability, the Court applied the doctrine that an offender is liable for the victim’s death even if the direct cause is a complication arising from the treatment of the inflicted wound, provided the wound is the proximate cause. The stab wound necessitated the surgery, and paralytic ileus was a direct and natural consequence of that surgical intervention. Thus, Reloj’s act was the proximate cause of death.
Regarding the qualifying circumstance, the attack was sudden and from behind, denying the victim any opportunity to defend himself. This manner of execution clearly constituted treachery (alevosia), properly qualifying the crime as murder. The Court rejected Reloj’s claim of incomplete self-defense as it was based solely on his uncorroborated testimony, which was inconsistent with the proven treacherous attack.
Finally, the Court found that the mitigating circumstance of voluntary surrender was duly proven. With this mitigating circumstance and no aggravating circumstance to offset it, the penalty should be imposed in its minimum period. The Court modified the sentence to an indeterminate penalty ranging from 10 years and 1 day of prision mayor to 17 years, 4 months and 1 day of reclusion temporal. The indemnity and accessory penalties were sustained.