Cause of the Evil Caused

“Hindi ko sinasadya” or “hindi ko ginusto ang nangyari” are defenses we will most likely invoke when confronted with an offense or wrong doing. But it might really be the case. Indeed, there are instances when we do things that go our of control and cause more damage than what was originally intended. A parent may have only intended to discipline but ended up seriously injuring his child. It may be used to mitigate but not to fully excuse criminal liability. The Revised Penal Code states that one of the mitigating circumstances is: “That the offender had no intention to commit so grave a wrong as that committed” (RPC, Article 13 paragraph 3).

Garcia vs. People

The story is very simple. This case is about a man punching another causing injuries to the victim who eventually died. The matter started with karaoke singing. Accused Amado together with some friends were engrossed in their karaoke singing that their neighbor Manuel had to tel them twice to stop because it was already late. Amado did not like what Manuel did. The same was repeated on another occasion. Again, Manuel admonished Amado and his friends to stop their karaoke since the neighborhood was being disturbed by their late night singing. The latter was now so infuriated by the constant castigation that he remarked to his friends that he wanted to “finish off” Manuel. On another drinking session Amado chanced upon Manuel who was getting out of his house. Upon confronting Manuel, Amado punched and kicked him several times until he fell to the ground. Manuel was able to retreat to his house and was able to call his wife. The police arrived followed by his wife who found his lifeless body. Amado was charged with murder then he was convicted for homicide. The Court of Appeals sustained the decision of the RTC then Amado appealed to the Supreme Court saying he did not cause Manuel’s death since the autopsy report states that he died of myocardial infarction (heart attack).

Cause of the Evil

The Supreme Court affirmed the conviction of Amado. The SC did not give credence to Amado’s defense since it was shown that Manuel’s heart attack was in fact caused by the physical violence he suffered from Amado. His claim that he did not intend to kill Manuel and that injuries inflicted were not fatal were merely considered as mitigating circumstances. Even though Amado might not have intended to kill Manuel, his act of injuring him with kick and fist blows ultimately resulted in Manuel’s heart attack which killed him. The High Court put it in this manner: “In this jurisdiction, a person committing a felony is responsible for all the natural and logical consequences resulting from it although the unlawful act performed is different from the one he intended; 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). Thus, the circumstance that petitioner did not intend so grave an evil as the death of the victim does not exempt him from criminal liability. (G.R. No. 171951, 28 August 2009).


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