People v Martin | 89 Phil. 18 | May 23, 1951



Facts: Aniceto Martin was found guilty of parricide for killing his wife, Laura Luiz, by strangling her with a rope inside the family toilet. He made a confession which he signed and swore to before the provisional fiscal. In this appeal the accused contends that the death of Laura was not due to the strangling, but to her heart disease, as stated in the testimony of Dr. De la Cuesta, resident Physician who performed the autopsy on the corpse of Laura. That the cause of death was heart failure due to fright or shock.

Issue: WON Aniceto Martin can still be held liable for the death of his wife even when the findings of the autopsy stated that the cause of death was not by strangling but due to the victims heart disease.

Ruling: It should be 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. A 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 shown), appellant’s assault being the proximate cause of the death, he would be responsible.

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