People vs Iligan y Jamito

FACTS:
In this appeal, uncle and nephew, Fernando Iligan and Edmundo Asis, seek a reversal of the
decision of the then Court of First Instance of Camarines Norte, Branch II 1 convicting them of
the crime of murder and sentencing them to suffer the penalty of reclusion perpetua and to
indemnify the heirs of Esmeraldo Quiones, Jr. in the amounts of P30,000 for the latters death
and P256,960 representing the victims unrealized income.

"That on or about 3:00 a.m., August 4, 1980, at sitio Lico II, barangay Sto. Domingo,
municipality of Vinzons, province of Camarines Norte, Philippines, and within the jurisdiction of
the Honorable Court, the above named accused, conspiring and mutually helping one another,
with treachery and evident premeditation, one of the accused Fernando Iligan armed with a bolo
(sinampalok) and with deliberate intent to kill, did then and there wilfully, unlawfully and
feloniously, gang up and in a sudden unexpected manner, hacked Esmeraldo Quiones, Jr., on his
face, thus causing fatal injuries on the latters face which resulted to (sic) the death of said
Esmeraldo Quiones.

ISSUE: WON the hacking of the head is the proximate cause of death? yes

HELD:
The hacking incident happened on the national highway 30 where vehicles are expected to pass
any moment. One such vehicle passed seconds later when Lukban and Zaldy Asis, running
scared and having barely negotiated the distance of around 200 meters, heard shouts of people.
Quiones, Jr., weakened by the hacking blow which sent him to the cemented highway, was run
over by a vehicle.

Under these circumstances, we hold that while Iligans hacking of Quiones, Jr.s head might not
have been the direct cause, it was the proximate cause of the latters death. Proximate legal cause
is defined as "that acting first and producing the injury, either immediately or by setting other
events in motion, all constituting a natural and continuous chain of events, each having a close
causal connection with its immediate predecessor, the final event in the chain immediately
effecting the injury as a natural and probable result of the cause which first acted, under such

circumstances that the person responsible for the first event should, as an ordinarily prudent and
intelligent person, have reasonable ground to expect at the moment of his act or default that an
injury to some person might probably result therefrom."
In other words, the sequence of events from Iligans assault on him to the time Quiones, Jr. was
run over by a vehicle is, considering the very short span of time between them, one unbroken
chain of events. Having triggered such events, Iligan cannot escape liability.

Decision:
WHEREFORE, appellant Fernando Iligan y Jamito is hereby convicted of the crime of homicide
for which he is imposed the indeterminate penalty of six (6) years and one (1) day of prision
mayor as minimum to fourteen (14) years, eight (8) months and one (1) day of reclusion
temporal medium as maximum