PEOPLE VS ADRIANO

763 SCRA 70 (2015)

FACTS: Adriano was charged with two (2) counts of Murder.
On or about March 13, 2007, around 8:00AM, in Malapit, San Isidro, NUEVA ECIJA, Adriano
together with 4 unknown men using a Corolla went down his car and shot Danilo Cabiedes
(ambushed) inside his CRV, and accidentally shot bystander Ofelia Bulanan due to a stray bullet.
The car used by Adriano was a Corolla rented from Rivera. Investigation was made where
Rivera admitted that he owns the car due to his car rental business and that he had it leased to
Adriano. When Adriano returned the Corolla to Rivera, he was then arrested.
Adriano was convicted for the murder of both Cabiedes and bystander Balunan.
ISSUE: WON Adriano is criminally liable for the death of Balunan
HELD: YES.
Adriano is guilty of the death of Bulanan under Article 4 of the Revised Penal Code.
Pursuant to the doctrine of aberratio ictus, which imposes criminal liability for the acts
committed in violation of law and for all the natural and logical consequences resulting
therefrom.
While it may not have been Adriano's intention to shoot Bulanan, this fact will not exculpate
him. Bulanan' s death caused by the bullet fired by Adriano was the natural and direct
consequence of Adriano's felonious deadly assault against Cabiedes.
One who commits an intentional felony is responsible for all the consequences which may
naturally or logically result therefrom, whether foreseen or intended or not. The rationale of
the rule is found in the doctrine, 'el que es causa de la causa es causa del mal causado ', or he
who is the cause of the cause is the cause of the evil caused.