GR 42117; (March, 1935) (Digest)
G.R. No. 42117 ; March 29, 1935
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. GREGORIO REYES, defendant-appellant.
FACTS
Gregorio Reyes was convicted of homicide for the death of Fausta Tavera. The deceased had been living with Reyes but returned to her parents, who demanded a dowry before marriage. On the evening of April 30, 1934, after a barrio procession and during a dance, Reyes and Tavera argued in the yard. When she informed him she would not return and was leaving with her parents, Reyes dragged her and stabbed her in the chest with a fanknife. She ran to a nearby house and died at the foot of the staircase. The wound was superficial, not penetrating the thoracic cavity, but the sanitary inspector certified death resulted from shock due to the wound. Reyes claimed he was attacked by the deceased’s relatives and any wounding was accidental during that affray.
ISSUE
1. Whether Reyes can be held criminally liable for homicide despite the superficial nature of the wound.
2. Whether the mitigating circumstances of lack of intent to commit so grave a wrong and sufficient provocation were correctly appreciated by the trial court.
RULING
1. Yes. A person is responsible for the consequences of their criminal act. The assault was the proximate cause of death, regardless of the wound’s superficiality or the deceased’s possible unknown health conditions. The doctrine of proximate cause applies, making the accused liable for homicide if the criminal act directly results in death.
2. No. The mitigating circumstances were erroneously applied. The use of a lethal weapon like a fanknife aimed at the chest contradicts a lack of intent to commit a grave wrong, as death is a natural consequence. Provocation must come from the offended party; the deceased’s refusal to renew the relationship or her relatives’ alleged attack does not constitute legal provocation by her.
The Supreme Court modified the judgment, finding Reyes guilty of homicide without aggravating or mitigating circumstances. He was sentenced under the Indeterminate Sentence Law to an indeterminate penalty of 8 years of prision mayor to 14 years, 8 months, and 1 day of reclusion temporal, and ordered to indemnify the heirs. The conviction was affirmed with modification.
AI Generated by Armztrong.