GR 28324 5; (May, 1978) (Digest)
G.R. Nos. L-28324-5 May 19, 1978
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAFAEL MARCO, SIMEON MARCO and DULCISIMO BELTRAN, defendants. RAFAEL MARCO, defendant-appellant.
FACTS
The incident occurred during a fiesta in Barrio Subang, Pagadian. Simeon Marco, son of appellant Rafael Marco, initiated a confrontation with Constancio Sabelbero, brandishing a knife and chasing him. As Constancio ran, Rafael struck him with a cane, an act for which Rafael was later convicted of slight physical injuries in a separate case. The altercation escalated when Vicente Sabelbero, Constancio’s father, intervened to disarm Simeon. Seeing Rafael armed and approaching, Vicente shouted for his sons to flee. Constancio and Vicente escaped, but Bienvenido Sabelbero, another son, was pursued by Rafael, who stabbed at him, wounding his left hand.
As Bienvenido continued to run, he tripped on a vine and fell. At this point, co-accused Dulcisimo Beltran, followed by Simeon Marco, arrived and successively stabbed the fallen Bienvenido, causing fatal wounds. Bienvenido managed to walk to a nearby store before collapsing and dying. Rafael Marco was convicted of murder by the trial court, which found him guilty as a co-conspirator for the killing committed by Beltran and Simeon.
ISSUE
Whether appellant Rafael Marco is criminally liable for the crime of murder for the death of Bienvenido Sabelbero, based on his initial act of stabbing the victim’s hand and the subsequent fatal attacks by his co-accused.
RULING
No. The Supreme Court modified the trial court’s decision, finding Rafael Marco guilty only of slight physical injuries. The Court ruled that there was no conclusive evidence of conspiracy between Rafael and the other assailants, Beltran and Simeon. Rafael’s criminal liability is limited to the direct and intended consequences of his own actions. The fatal wounds inflicted on Bienvenido were not the natural and logical result of Rafael’s act of wounding the victim’s hand.
The Court emphasized that an intervening cause—the sudden, independent, and successive attacks by Beltran and Simeon after the victim fell—broke the chain of causation from Rafael’s initial assault. In the absence of proof of a common criminal design, Rafael cannot be held responsible for the acts of others that he did not orchestrate. His failure to join the final attack suggested a lack of homicidal intent. Consequently, with no evidence regarding the required medical attendance or incapacity from the hand wound, his liability is limited to slight physical injuries. The penalty was reduced to twenty days of arresto menor.