Aniceto Martin was found guilty of killing his wife Laura by strangling her with a rope. Her autopsy showed the cause of death was heart failure due to fright or shock from being strangled. Martin appealed, arguing the means he used did not directly kill her. The court modified the ruling, finding Martin responsible for Laura's death because strangling her directly caused the heart failure, even if she was already sick. Precedent establishes that one is responsible for the consequences of criminal acts, and an illegal aggressor is not relieved of responsibility if a victim's preexisting condition contributed to their death.
Aniceto Martin was found guilty of killing his wife Laura by strangling her with a rope. Her autopsy showed the cause of death was heart failure due to fright or shock from being strangled. Martin appealed, arguing the means he used did not directly kill her. The court modified the ruling, finding Martin responsible for Laura's death because strangling her directly caused the heart failure, even if she was already sick. Precedent establishes that one is responsible for the consequences of criminal acts, and an illegal aggressor is not relieved of responsibility if a victim's preexisting condition contributed to their death.
Aniceto Martin was found guilty of killing his wife Laura by strangling her with a rope. Her autopsy showed the cause of death was heart failure due to fright or shock from being strangled. Martin appealed, arguing the means he used did not directly kill her. The court modified the ruling, finding Martin responsible for Laura's death because strangling her directly caused the heart failure, even if she was already sick. Precedent establishes that one is responsible for the consequences of criminal acts, and an illegal aggressor is not relieved of responsibility if a victim's preexisting condition contributed to their death.
Aniceto Martin was found guilty of killing his wife Laura by strangling her with a rope. Her autopsy showed the cause of death was heart failure due to fright or shock from being strangled. Martin appealed, arguing the means he used did not directly kill her. The court modified the ruling, finding Martin responsible for Laura's death because strangling her directly caused the heart failure, even if she was already sick. Precedent establishes that one is responsible for the consequences of criminal acts, and an illegal aggressor is not relieved of responsibility if a victim's preexisting condition contributed to their death.
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G.R. No.
L-3002 May 23, 1951
PEOPLE vs. ANICETO MARTIN
FACTS: On August 1, 1948, the corpse of Laura was found inside the family toilet, which was at a certain distance from their home, with a maguey rope, six meters long and one centimeter in diameter, around her neck. Upon being interrogated by the police officer, the defendant at first denied any knowledge of the event, but later promised to make a statement in the municipal building. The defendant made a confession that he killed his wife. They had been arguing and she came after him to the toilet with a rope in her hands and, as she approached him she placed around his neck the rope, which angered him so he snatched the rope from her, and in turn placed same around her neck, and in that position tightened the rope and his wife died. The autopsy on the corpse of Laura issued a certificate which stated that the cause of death was heart failure due to fright or shock. Aniceto Martin was found guilty of parricide by the Court of First Instance of Ilocos Norte.
ISSUE: W/N the defendant must be found guilty of parricide, even though the means he employed did not kill his wife, but the resulting heart failure. HELD: The Court modified the decision of the lower court. The court noted that the heart failure was due to the fright or shock caused by the strangling, and consequently, the defendant was responsible for the death, notwithstanding the fact that the victim was already sick. Had not the defendant strangled the deceased, the latter, notwithstanding her illness, would not have died. In other words, the defendant directly caused her death. In the case of People vs. Reyes (61 Phil. 341, 343,) the Court held that person is responsible for the consequences of his criminal act and even if the deceased had been shown to be suffering from a diseased heart (which was not shown), appellants assault being the proximate cause of the death, he would be responsible. Moreover, in the case of U.S. vs. Brobst (14 Phil. 310), the following doctrine was established: where death results as the direct consequences of the use of illegal violence, the mere fact that the diseased or weakened condition of the injured person contributed to his death, does not relieve the illegal aggressor of criminal responsibility.