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People vs. Iligan Case Digest

Fernando Iligan, Edmundo Asis, and Juan Macandog attacked Esmeraldo Quiñones, Jr., Zaldy Asis and Felix Lukban with a bolo. Fernando Iligan hacked Quiñones in the forehead, causing him to fall. Quiñones was then run over and killed by a passing vehicle. The court held Fernando Iligan criminally liable for Quiñones' death, as his attack with the bolo was the proximate cause, even if the vehicle was the direct cause. While the autopsy found the hacking wound superficial, the court noted the location on a busy highway meant Quiñones' death was a direct, natural, and logical

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2K views

People vs. Iligan Case Digest

Fernando Iligan, Edmundo Asis, and Juan Macandog attacked Esmeraldo Quiñones, Jr., Zaldy Asis and Felix Lukban with a bolo. Fernando Iligan hacked Quiñones in the forehead, causing him to fall. Quiñones was then run over and killed by a passing vehicle. The court held Fernando Iligan criminally liable for Quiñones' death, as his attack with the bolo was the proximate cause, even if the vehicle was the direct cause. While the autopsy found the hacking wound superficial, the court noted the location on a busy highway meant Quiñones' death was a direct, natural, and logical

Uploaded by

Claribel Domingo Bayani
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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PEOPLE OF THE PHILIPPINES v.

FERNANDO ILIGAN y JAMITO, EDMUNDO ASIS


y ILIGAN and JUAN MACANDOG
G.R. No. 75369, November 26, 1990

Facts:
One morning Esmeraldo Quiñones, Jr., Zaldy Asis and Felix Lukban, were walking home
they met the accused Fernando Iligan, his nephew, Edmundo Asis, and Juan Macandog.
Edmundo Asis pushed them aside thereby prompting Zaldy Asis to box him. Fernando Iligan,
upon seeing his nephew fall, drew from his back a bolo and hacked Zaldy Asis but missed.
Terrified, the trio ran pursued by the three accused. They ran for about half an hour and they
stopped running only upon seeing that they were no longer being chased. While the trio were
walking towards the house of Quiñones, Jr., the three accused suddenly emerged on the roadside,
Fernando Iligan hacked Quiñones, Jr. with his bolo hitting him on the forehead and causing him
to fall down. Horrified, Felix Lukban and Zaldy Asis fled to a distance of 200 meters, but
returned walking after they heard shouts of people and saw him already dead with his head
busted.
The body of Quiñones, Jr. was autopsied by Dr. Marcelito E. Abas and the postmortem
examination report reveals that Quiñones, Jr. died of shock and massive cerebral hemorrhages
due to a vehicular accident.
Issue:
Whether or not the accused are liable for the victim’s death given it was due to a
vehicular accident and not the hacking.
Held:
The court held that the accused Fernando Iligan is liable and convicted of the crime
homicide. The court is convinced beyond peradventure that indeed, after Quiñones, Jr. had fallen
from the bolo-hacking perpetrated by Iligan, he was run over by a vehicle. This finding,
however, does not in any way exonerate Iligan from liability for the death of Quiñones, Jr.c
Under Article 4 of the Revised Penal Code, criminal liability shall be incurred "by any person
committing a felony (delito) although the wrongful act done be different from that which he
intended." Based on the doctrine that "el que es causa de la causa es causa del mal causado" it
means he who is the cause of the cause is the cause of the evil caused, the essential requisites of
Article 4 are: (a) that an intentional felony has been committed, and (b) that the wrong done to
the aggrieved party be the direct, natural and logical consequence of the felony committed by the
offender and hold that these requisites are present in this case.
There is intentional felony committed and that was the hacking of the head of Quiñones,
Jr. by Iligan though it was considered as superficial by the physician who autopsied Quiñones. It
is the location of the wound by the instrument used in the assault. It is important to note that the
hacking incident happened on the national highway 30 where vehicles are expected to pass any
moment. The court held that while Iligan’s hacking of Quiñones, Jr.’s head might not have been
the direct cause but it was the proximate cause of the latter’s death. Appellant Fernando Iligan y
Jamito is convicted while Edmundo Asis is acquitted.

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