Prepared by :

Alexander B. Olila / 071915

Case

People v. Cornel, 78 Phil. 458, G.R. No. L-204, May 16, 1947,

Ponente

Paras, J.

Doctrine

Revised Penal Code Art. 4.1. Criminal liability shall be incurred

by a person committing a felony (delito) although the wrongful
act done be different form that which he intended.

Facts

The appellant, who was initially prosecuted for physical injuries

prior to the death of the Fabian Burac, was eventually convicted
for the crime of homicide by the judgment of the Court of First
Instance of Albay.
The appeal was based on two arguments. Firstly, the alleged
inadequacy of evidence for the prosecution to establish the
appellants identity and secondly, that the cause of death of the
victim is possibly because of other diseases which may exhibit
tetanus-like symptoms. The identity of the assailant was
established through testimonies of the victims wife and motherin-law which the court accepted to be truthful. The victim
survived the initial injuries sustained from a bolo hacked to the
forehead and stone struck thereafter to the right clavicle caused
by the appellant. However, the victim eventually died of tetanus
few days after because it was not available at the time.

Issue/s

Is the defendant still liable for the death of the victim when the
cause of death is a direct, natural and logical consequence of
the committed felony?
Is the criminal intent justified by the appellants motive to cause
injury to the deceased victim of crime (homicide)?

Held

The Supreme Court ruled that the appellants defense of alibi of

not being present during the time of the incident would have
been worth investigating if the wife was not an eyewitness to
the criminal offense. They added that the victim certainly died of
tetanus as a complication of the felony committed by the
appellant. Because of this, the appellant must be held liable for
the natural consequences of his unlawful act. Furthermore, the
motive for the offense was determined by the circumstance that
the deceased victim once arrested and threatened the appellant
during the Japanese occupation.