People v. Villacorta, GR No.

186412, September 7, 2011

Facts:
On January 22, 2002, Danilo Cruz went to a sari-sari store to buy bread. Out of nowhere, Orlito
Villacorta appeared and thereafter stabbed the left part of the body of Cruz with a sharpened
bamboo stick. After that, Villacorta fled. Cruz was helped by bystanders and he was brought to a
nearby hospital where he was treated as out-patient. He was discharged on the same day but
on February 14, 2002, or 21 days after the stabbing incident, he returned to the same hospital
where he was treated for severe tetanus. The next day on February 15, 2002, Cruz died. The
medical report states that Cruz died of tetanus infection secondary to stab wound. The trial court
as well as the Court of Appeals convicted Villacorta for murder.
Issue:
Whether or not Villacorta is guilty of murder.
Ruling:
No. In this case, the proximate cause of the death is not the stabbing done by Villacorta upon
Cruz. There was an efficient intervening cause which appeared between the time of the
stabbing and the time of the death of Cruz. In explaining this, the Supreme Court took into
consideration the fact that severe tetanus (the kind of tetanus which causes immediate death)
has an incubation period of 14 days or less. In this case, the stabbing made by Vilalcorta could
not have caused the tetanus infection as 22 days already lapsed from the time of the stabbing
until the date of death of Cruz. Something else caused the tetanus other than the stabbing in
short, Cruz acquired the tetanus 14 days or less before February 15, 2003 and not on the date
of stabbing. The court explained further: The rule is that the death of the victim must be
the direct, natural, and logical consequence of the wounds inflicted upon him by the
accused. And since we are dealing with a criminal conviction, the proof that the accused caused
the victims death must convince a rational mind beyond reasonable doubt. The medical
findings, however, lead us to a distinct possibility that the infection of the wound by tetanus was
an efficient intervening cause later or between the time Cruz was wounded to the time of his
death. The infection was, therefore, distinct and foreign to the crime. Villacorta is however guilty
of slight physical injuries based on the facts. Neither is he guilty of attempted nor frustrated
murder, his intent to kill was not proven by the prosecution.