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Urbano v.

IAC

FACTS
 On October 23, 1980, petitioner Filomeno Urbano was on his way to his ricefield when he discovered
that the place where he stored palay was flooded with water coming from an irrigation canal. When he
investigated the area, he saw Marcelino Javier and Emilio Efre.
o Javier admitted that he opened the irrigation canal. A quarrel ensued, and Urbano started to
hack Javier with a bolo. Javier was wounded at the right palm of his hand. Upon intervention,
Urbano and Javier had an amicable settlement.
o Urbano agreed to shoulder all the expenses for the medication of the wound of Javier, as well
as to pay also whatever loss of income Javier may have suffered. Javier, on the other hand,
signed a statement of his forgiveness towards Urbano and on that condition, he withdrew the
complaint that he filed against Urbano.
o After several weeks of treatments and medication, the doctor pronounced that the wound of
Javier was already healed.
 However, on November 14, 1980, Javier was rushed to the hospital when he had sudden lockjaw and
convulsions. The doctor found the condition to be caused by tetanus toxin which infected from the
healing wound in his right palm of his hand. The following day, on November 15, 1980, Javier died. 
o The heirs of Javier filed a case of homicide against Urbano. Urbano was charged with homicide
and was found guilty both by the trial court and on appeal by the IAC.
o Urbano then filed a motion for a new trial based on the affidavit sworn by the Barangay Captain
who stated that he saw the deceased catching fish in the shallow irrigation canals on November
5. – DENIED

ISSUE + RULING
May the wound inflicted by Urbano on Javier may be considered as the proximate cause of the latter’s death?
NO.
 The Court defined proximate cause as “that cause which, in natural and continuous sequence,
unbroken by any efficient intervening cause, produces the injury, and without which the result would not
have occurred.”
o In this case, the death of the victim must be the direct, natural, and logical consequence of the
wounds inflicted upon him by the accused. And since we are dealing with a criminal conviction,
the proof that the accused caused the victim’ s death must convince a rational mind beyond
reasonable doubt.
 The Court ruled that Urbano is not liable for the death of Javier. Urbano is only liable for the physical
injuries inflicted to Javier through the wound on the right palm of his hand. The Court took into account
the average incubation period of tetanus toxin, and medical evidence indicated that patients affected
with tetanus experience its symptoms within 14 days.
o If, indeed, Javier had incurred tetanus poisoning out of the wound inflicted by Urbano, he would
not have experienced the symptoms on the 23rd day after the hacking incident. The medical
findings lead to a distinct possibility that the infection of the wound by tetanus was an efficient
intervening cause later or between the time Javier was wounded to the time of his death. The
infection was, therefore, distinct and foreign to the crime.
o However, the act of Javier working in his farm where the soil is filthy, using his own hands, is an
efficient supervening cause which relieves Urbano of any liability for the death of Javier.
o There is a likelihood that the wound was but the remote cause and its subsequent infection, for
failure to take necessary precautions, with tetanus may have been the proximate cause of
Javier's death with which the petitioner had nothing to do.

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