G.R. No. 171951; August 28, 2009
AMADO ALVARADO GARCIA, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner Amado Garcia was charged with murder for the death of Manuel Chy. The prosecution established that on September 26, 1999, Garcia became irate after Chy asked his group to lower their videoke volume, uttering threats against Chy. On September 29, 1999, Garcia summoned Chy from his house, suddenly punched him, and continued the assault. Garcia struck Chy on the head with a beer bottle, after which Chy fell when shoved by a companion. Chy managed to flee home, called his wife to report the mauling and his difficulty breathing, and was later found unconscious. He was pronounced dead on arrival at the hospital. The autopsy report listed the cause of death as myocardial infarction.
The Regional Trial Court convicted Garcia of the lesser crime of homicide, a ruling affirmed by the Court of Appeals. Garcia appealed to the Supreme Court, arguing he should not be liable for Chy’s death as the direct cause was a heart attack, not the injuries from the mauling.

ISSUE

Whether petitioner Amado Garcia is criminally liable for the death of Manuel Chy, considering that the immediate cause of death was myocardial infarction.

RULING

Yes, the petitioner is liable for homicide. The Supreme Court affirmed the conviction, applying the doctrine of proximate cause. Legal logic dictates that a person is criminally responsible for a result if his felonious act was the proximate cause of the death. 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.
The Court found that the myocardial infarction was directly triggered by the physical attack and the resulting fright or shock. The medical testimony confirmed that the stress from the mauling—the physical exertion from defending himself, the blows, and the emotional trauma—could induce a heart attack, especially in a susceptible individual. There was no evidence of any independent intervening cause that broke the chain of events from the assault to the fatal heart attack. Therefore, Garcia’s unlawful aggression was the proximate cause of Chy’s death. The absence of an intent to kill does not negate liability for homicide, as the crime is consummated by the death resulting from the accused’s deliberate act. The mitigating circumstance of lack of intent to commit so grave a wrong was correctly appreciated, warranting the penalty imposed within the minimum period.