G.R. No. L-72964. January 7, 1988.
FILOMENO URBANO, petitioner, vs. HON. INTERMEDIATE APPELLATE COURT AND PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner Filomeno Urbano was convicted of homicide for the death of Marcelo Javier. The incident began on October 23, 1980, when Urbano, angered that Javier had opened an irrigation canal causing his palay to be soaked, confronted Javier. A quarrel ensued, during which Urbano hacked Javier on the right palm with a bolo. Javier ran but was overtaken and hit on the leg with the back of the bolo. Urbano was prevented from further attack by his daughter. Javier was treated by a doctor for an incised wound on his palm. The parties, through barangay intercession, settled amicably on October 27, 1980, with Urbano agreeing to pay Javier’s medical expenses. Urbano made payments on October 27 and November 3.
On November 14, 1980, Javier was rushed to the hospital with lockjaw and convulsions. Dr. Edmundo Exconde diagnosed tetanus, noting a healing wound on Javier’s palm as the possible entry point for infection. Javier died on November 15, 1980. The prosecution’s theory was that the tetanus infection originated from the wound inflicted by Urbano, leading to Javier’s death. The trial court and the Intermediate Appellate Court found Urbano guilty, holding him criminally liable for homicide.

ISSUE

Whether the petitioner’s criminal liability for homicide was established beyond reasonable doubt, given the intervening cause of death and the prior amicable settlement between the parties.

RULING

The Supreme Court acquitted Urbano, reversing the appellate court’s decision. The Court held that the prosecution failed to prove the direct causal connection between Urbano’s infliction of the wound and Javier’s death from tetanus beyond a reasonable doubt, which is required for criminal conviction. The Court emphasized that for criminal liability to attach, the accused’s act must be the proximate cause of the death. Here, death resulted from tetanus, a supervening cause that was not proven to be the natural and direct consequence of the wound.
The medical evidence did not conclusively establish that the wound was infected at the time of infliction or that the tetanus bacillus was introduced by Urbano’s bolo. The wound had been healing, and Javier had been medically treated. The death occurred over three weeks after the incident, during which other potential sources of infection could not be ruled out. The Court found reasonable doubt as to whether the death was directly attributable to Urbano’s criminal act, as opposed to an intervening, independent cause. The prior amicable settlement, while not a defense to the criminal charge, underscored the initial non-fatal nature of the injury. The acquittal is without prejudice to any separate civil action for damages, as civil liability is separate and distinct from criminal liability and requires only a preponderance of evidence.