Urbano vs. Intermediate Appellate Court G.R. No. 72964, 7 Januar !9"" Criminal #a$ ! Case %i&est 'AC()*
On October 23, 1980, peoner Filomeno Urbano (Urbano) was on his way to his ricefel when he isco!ere that the place where he store palay was "ooe with water comin# $rom an irri#aon canal% &hen he in!es#ate the area, he saw 'arcelino a!ier (a!ier) an milio $re ($re)% a!ier ami*e that he opene the irri#aon canal% + -arrel ens-e, an Urbano starte to hac. a!ier with a bolo% a!ier was wo-ne at the ri#ht palm o$ his han% Upon inter!enon, Urbano an a!ier ha an amicable se*lement% Urbano a#ree to sho-ler all the e/penses $or the meicaon o$ the wo-n o$ a!ier, a!ier, as well as to pay also whate!er loss o$ income a!ier may ha!e s-ere% a!ier, a!ier, on the other han, si#ne a statement o$ his $or#i!eness towars Urbano an on that conion, he withrew the complaint that he fle a#ainst Urbano% +er se!eral wee.s o$ treatments an meicaon, the octor prono-nce that the wo-n o$ a!ier was alreay heale% owe!er, owe!er, on o!ember 14, 1980, a!ier was r-she to the hospital when he ha s-en loc.5aw an con!-lsions% 6he octor $o-n the conion to be ca-se by tetan-s to/in which in$ecte in$ecte $rom the healin# wo-n in his ri#ht palm o$ his han% 6he $ollowin# ay, ay, on o!ember 17, 1980, a!ier ie% 6he heirs o$ a!ier fle a case o$ homicie a#ainst Urbano% Urbano was char#e with homicie an was $o-n #-ilty both by the trial co-rt an on appeal by the ntermeiate +ppellate +ppellate o-rt% Urbano then fle a moon $or a new trial base on the a:a!it sworn by the ;aran#ay ;aran#ay aptain who state that he saw the ecease catchin# fsh in the shallow irri#aon canals on o!ember 7% 6he moon was enie by the responent co-rt% ence, this peon% I))U+)* &hether or not t he wo-n in"icte by Urbano to a!ier may be consiere as the pro/imate ca-se o$ the la*er occ-rre%> n this case, the eath o$ the !icm m-st be the irect, nat-ral, an lo#ical conse-ence o$ the wo-ns in"icte -pon him by the acc-se% +n since we are ealin# with a criminal con!icon, the proo$ that the acc-se ca-se ca-se the !icm< !icm<s eath eath m-st m-st con!ince con!ince a raonal raonal min beyon beyon reason reasonable able o-bt o-bt%% 6he o-rt r-le that Urbano is not liable $or the eath e ath o$ a!ier% a!ier% Urbano is only liable $or the physical in5-ries in"icte to a!ier thro-#h the wo-n on the ri#ht palm o$ his han% 6he o-rt too. into acco-nt the a!era#e inc-baon perio o$ tetan-s to/in, an meical e!ience inicate that paents aecte with tetan-s e/perience its symptoms within 14 ays% $, inee, a!ier ha inc-rre tetan-s poisonin# o-t o$ the wo-n in"icte by Urbano, he wo-l not ha!e e/perience the symptoms on the 23r ay aer the hac.in# incient% 6he meical fnin#s lea to a isnct possibility that the in$econ o$ the wo-n by tetan-s was an e:cient inter!enin# ca-se later or between the me a!ier was wo-ne to the me o$ his eath% 6he in$econ was, there$ore, isnct an $orei#n to the crime% owe!er, owe!er, the act o$ a!ier wor.in# in his $arm where the soil is flthy, flthy, -sin# his own hans, is an e:cient s-per!enin# ca-se which relie!es Urbano o$ any liability $or the eath o$ a!ier% a!ier% 6here is a li.elihoo that the wo-n was b-t the remote ca-se an its s-bse-ent in$econ, $or $ail-re to ta.e necessary preca-ons, with tetan-s may ha!e been the pro/imate ca-se o$ a!ier?s eath with which the peoner ha nothin# to o% &@FO@, the instant peon is hereby A@+6B% 6he -esone ecision o$ the then ntermeiate +ppellate +ppellate o-rt, now o-rt o$ +ppeals, is @C@DB an D6 +DB% 6he peoner is +EU66B o$ the crime o$ homicie%
