GR No. 75369.

November 26, 1990

Pp [plaintiff-appellee] vs Iligan [defendant-appellant]

Issue: Whether or not accused are liable for victims death given that the death was due to vehicular
accident and not hacking

Held: Yes. Under Art. 4 of the RPC, Criminal liability shall be incurred: 1. By any person committing a
felony (delito) although the wrongful act done be different from that which he intended.

While the intentional felony of hacking Quinones head by Iligan might not have been the direct cause, it
was the proximate cause of Quinones death. The sequence of events from Iligans assault on Quinones
to the time Quinones 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.

SC also stated that prosecution failed to prove the aggravated circumstances of treachery and evident
premeditation.

Wherefore, appellant Iligan is convicted of the crime of homicide for which he is imposed the
indeterminate penalty of 6 years and 1 day of prison mayor as minmum to 14 years 8 months and 1 day
of reclusion temporal medium as maximum and he shal indemnify the heirs of Quinones in the amount
of Php50,000. Appellant Edmund Asis is Acquitted of the charge against him. Costs against Iligan.

Facts:

Esmeraldo Quinones and his companions (Zaldy Asis & Felix Lucban) were walking home from
attending a barrio fiesta. On the way they met Fernando Iligan and his nephew Edmundo Asis
and Juan Macandong.
Edmundo Asis pushed Quinones group aside prompting Zaldy to box Edmundo. Felix said they
have no desire to fight.
Upon seeing his nephew fall, Iligan pulled a bolo and hacked Zaldy but missed.
Quinones group ran away followed by Iligans group. They stopped running after half an hour
when they saw they were not being chased anymore.
While Quinones group was on the way home, Iligans group suddenly emerged on the roadside
and without a word, Iligan hacked Quinones, hitting him on the forehead and causing him to fall
down. Felix and Zaldy fled but returned walking after they heard shouts of people.
On the spot where Quinones was hacked, Felix and Zaldy saw him already dead with the head
busted.
Quinones was autopsied by a Dr. Marcelito Abas. Aside from the injuries, the death certificate
also indicates that Quinones died due to vehicular accident.
The Defendants denied the crime stating that they were in their respective houses when the
crime was committed. (Iligan and Edmundo, Juan was still at large). The defense made capital
the testimony of Dr. Abas that Quinones died because of a vehicular accident.
 The lower court found that Iligans group conspired to kill anyone or all members of Quinones
group due to aggravating circumstances of evident premeditation and treachery and convicted
Iligan and Edmundo of the crime of murder
Iligan and Edmundo filed for appeal professing innocence.