Here are select November 2012 rulings of the Supreme Court of the Philippines on criminal law and procedure:
1. REVISED PENAL CODE
Proximate cause; definition. The Supreme Court rejected the argument of petitioners that the Court of Appeals failed to consider in its entirety the testimony of the doctor who performed the autopsy. What really needs to be proven in a case when the victim dies is the proximate cause of his death. Proximate cause has been defined 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.” The autopsy report indicated that the cause of the victim’s death is multiple organ failure. According to Dr. Wilson Moll Lee, the doctor who conducted the autopsy, it can be surmised that multiple organ failure was secondary to a long standing infection secondary to a stab wound which the victim allegedly sustained. Thus, it can be concluded that without the stab wounds, the victim could not have been afflicted with an infection which later on caused multiple organ failure that caused his death. The offender is criminally liable for the death of the victim if his delictual act caused, accelerated or contributed to the death of the victim. Rodolfo Belbis Jr. y Competente and Alberto Brucales v. People of the Philippines, G.R. No. 181052, November 14, 2012.
Rape; qualifying circumstances; concurrence of minority and relationship. Under Article 266-B of the Revised Penal Code, as amended by R.A. No. 8353 or the Anti-Rape Law of 1997, the concurrence of minority and relationship qualifies the crime of rape. To warrant the imposition of the death penalty, however, both the minority and the relationship must be alleged in the Information and proved during the trial. In the instant case, both circumstances were properly alleged in the Informations and proved during trial. The Informations alleged that AAA was 15 years old when the crimes were committed. Her minority was established not only by her Certificate of Live Birth but also by her testimony that she was born on November 6, 1985. Anent AAA’s relationship with appellant, the Informations sufficiently alleged that AAA is appellant’s daughter. This fact was likewise openly admitted by the appellant and further bolstered by the said Certificate of Live Birth indicating appellant as AAA’s father. Moreover, the relationship between appellant and AAA became the subject of admission during the pre-trial conference. Hence, pursuant to the said article, the presence of the above special qualifying circumstances increases the penalty to death. In view, however, of the passage of R.A. No. 9346 proscribing the imposition of death penalty, the proper penalty imposable on appellant, in lieu of death and pursuant to Section 2 thereof, is reclusion perpetua. People of the Philippines v. Enerio Ending y Onyong, G.R. No. 183827, November 12, 2012.