PEOPLE V ILAGAN then charged with the crime of murder with
GR NO. 75369 aggravating circumstances of evident
NOVEMBER 26, 1190
PETITONERS/PROSECUTORS: People of the
Philippines
RESPONDENTS/DEFENDANTS: Fernando Ilagan y
Jamito, Edmundo Asis y Ilagan, and Juan Macandog
TOPIC:
 Wrongful done be different from what was
intended
TERMS:
 Proximate legal cause- “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.”
LAWS/PROVISIONS:
 Article 4, Par. 1 of the RPC: “Criminal liability
shall be incurred:
o By any person committing a felony
although the wrongful act done be
different from that which he intended”
FACTS:
 August 4, 1980 – After a barrio fiesta in Vinzons,
Camarines Norte, Edmundo pushed aside the
group of Esmeraldo Quinones, Jr., Zaldi Asis,
and Felix Lukban, and even prompted Zaldi to
box. Fernando brought out his bolo when he saw
Edmundo on the ground, hacked Zaldi but
missed. The group of Quinones was then
pursued by the three accused.
 Upon seeing they were no longer being chased,
Quinones invited the other two to his house so
that he could change to his working clothes as a
bus conductor.
 While the trio were walking along a national
highway towards the victim’s house, the three
accused suddenly emerged on the road side.
That was the time when Fernando hacked
Quinones, Jr. on his face, causing fatal injuries
on the latter’s face which resulted in his death.
 The accused denied having perpetrated the
crime and stated that they were on their
respective houses when the crime occurred.
 The lower court found that Iligan’s group
conspired to kill anyone or all members of the
group of the victim to vindicate the boxing on the
face of Edmundo. Fernando and Edmundo were
premeditation and treachery.
ISSUES:
 WON Fernando could be absolved of his
criminal liability given that the victim was
subsequently run over by a vehicle
RULING:
 1st issue: Denied.
 Based on the doctrine: “el que es causa de la
causa es causa del mal causado” (he who is the
cause of the cause is the cause of the evil
caused), the essential requisites of Article 4 are:
(a) that an intentional felony has been
committed, and (b) that the wrong done to the
aggrieved party be the direct, natural and
logical consequence of the felony committed
by the offender. These requisites are present in
this case. The intentional felony was the hacking
by Fernando.
 The second requisite was also met. Given that
the incident happened on a national highway
where vehicles are expected to pass,
Fernando’s hacking of Quinones’s head was the
proximate, might not be direct, cause of the
latter’s death. The sequence of events from
Fernando’s assault to the time Quinones was
run over by a vehicle is one unbroken chain of
events. With that said, it did not really matter if
he directly caused Quinones’s death or if he
actually meant it. Having triggered such events,
Iligan cannot escape liability even though the
autopsy indicated that the death was caused by
a vehicular accident.
 Since treachery and evident premeditation were
not established, the lower court’s charge for
Fernando was modified from murder to
homicide.
 However, it was not clearly established that
Edmundo took any direct part in the hacking
incident since mere knowledge/approval of the
act without cooperation is not enough to charge
him a co-principal. Therefore, he deserved
exoneration.