G.R. No. 35006; September 7, 1931
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. PURIFICACION ALMONTE, defendant-appellant.

FACTS

The accused, Purificacion Almonte, was charged with homicide for stabbing her former paramour, Felix Te Sue, with a penknife in the abdomen. They had separated a week prior, after which Te Sue lived with another woman, Miguela Dawal. On the day of the incident, the accused visited Te Sue, was told to leave, and after being pushed by Te Sue and Dawal, she stabbed him. The wound was initially assessed by the attending physician as not serious and likely to heal within a week with proper care. However, the deceased, while hospitalized, made unnecessary movements against medical advice, citing discomfort from the warm bed. These movements caused a secondary internal hemorrhage, from which he died six days after the stabbing.

ISSUE

Whether the accused is criminally liable for the death of Felix Te Sue, considering that the fatal secondary hemorrhage was caused by the victim’s own unnecessary movements in the hospital.

RULING

No. The Supreme Court modified the trial court’s judgment. The accused is liable only for less serious physical injuries (lesiones menos graves), not homicide. The direct, immediate, and proximate cause of death was the secondary hemorrhage, which resulted from the victim’s own voluntary and unnecessary movements against medical advice, and not from the wound itself. The wound was not mortal and would have healed within a week had the victim remained still. Following the doctrine that an accused is only liable for the natural and proximate consequences of their unlawful act, the court held that the death was an independent, intervening cause attributable to the victim’s own negligence. The penalty was reduced to arresto menor.

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