Mario Halimuyak was then charged for the murder of Anna Kay. Mario interposed the defense that the stab wound sustained by Anna Kay was not the proximate cause of her death, rather it was the infection of the wound by tetanus
One night, at around ten o'clock in the evening, Anna Kay Teteng was eating her meal while her parents Ka Teteng and Ma Teteng were upstairs binge watching their favorite Korean drama series, Stairway to Heaven.
While Anna Kay was eating, Mario Halimuyak entered their house through the kitchen's door and immediately stabbed Anna Kay from behind using a rusty knife. Mario covered her mouth and whispered, "Putangina mong babae ka. Napakatsismosa mo. Sige Mag-ingay ka para maturuan ka ng leksyon." Anna Kay pleaded him to stop, but Mario ignored her plea. He stabbed her in the chest then left.
Thirty minutes after, Ka Teteng saw Anna Kay lying in their kitchen covered in blood. He asked her who stabbed her, and Anna Kay answered, "Mario Halimuyak." Anna Kay was rushed to the nearest hospital where she immediately died.
Mario Halimuyak was then charged for the murder of Anna Kay. Mario interposed the defense that the stab wound sustained by Anna Kay was not the proximate cause of her death, rather it was the infection of the wound by tetanus.
This begs the question"Namatay ba ang Anak ni Teteng sa Tetano?"
The rule is that the death of the victim must be direct, natural, and logical consequences of the wounds inflicted upon him by the accused. 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. Urbano v. Intermediate Appellate Court (1988)
In People v. Cornel (1947), if the victim died due to tetanus of which he was infected at the precise moment when the accused inflicted injuries upon the victim or immediately thereafter, the crime would either be homicide/murder, depending on the presence of qualifying circumstances.
On the contrary, if there is an efficient intervening cause, the accused may only be convicted of physical injuries, the penalty of which would depend on the severity of the wound inflicted.
In Villacorta v. People (2011), there had been an interval of 22 days between the date of the stabbing and the date when the victim died. The Supreme Court ruled that the stab wound was merely the remote cause, and its subsequent infection with tetanus might have been the proximate cause of the victim's death. The infection of the victim's stab wound by tetanus was an efficient intervening cause later or between the time the victim was stabbed at the time of his death. The Accused was held liable for slight physical injuries.
In Mario's case, Anna Kay almost immediately succumbed to her injuries. Thus, even assuming that tetanus was the real cause of her death, there is no efficient cause that intervened between the stabbing done by Mario and Anna Kay's death. Mario should be held liable for homicide/murder, depending on the presence of qualifying circumstances.
In sum, it is important to know what the exact cause of a person's death in order to determine the exact liability of an accused.
