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People V Acuram (Efficient Intervening Cause)

The court ruled that lack of prompt medical attention was not an efficient intervening cause that exempted the appellant from criminal responsibility. While the appellant claimed the victim died due to negligent medical treatment, he provided no evidence of negligence. The attending doctors testified they did their best to treat the victim, including blood transfusions and surgery. Even if medical treatment had been delayed, that would not break the causal connection between the appellant's shooting and the victim's death. The proximate cause of death was the gunshot wound, not any alleged lack of proper medical care.

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558 views2 pages

People V Acuram (Efficient Intervening Cause)

The court ruled that lack of prompt medical attention was not an efficient intervening cause that exempted the appellant from criminal responsibility. While the appellant claimed the victim died due to negligent medical treatment, he provided no evidence of negligence. The attending doctors testified they did their best to treat the victim, including blood transfusions and surgery. Even if medical treatment had been delayed, that would not break the causal connection between the appellant's shooting and the victim's death. The proximate cause of death was the gunshot wound, not any alleged lack of proper medical care.

Uploaded by

Adrian Olaguer Aguas
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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G.R. No.

117954 April 27, 2000

PEOPLE OF THE PHILIPPINES, plaintiff-appellee,


vs.
ORLANDO ACURAM, accused-appellant.

Proximate cause is "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."
(Bataclan vs. Medina, 102 Phil. 181, 186, quoting 38 Am. Jur. 695)

Efficient intervening causes, do breaks


the relation of cause and effect — the felony committed and the resulting
injury.

FACTS

- on June 29, 1991, at around seven o'clock in the evening, Rolando Manabat, Oscar Manabat,
Bartolome Nabe, and Peterson Valendres, after the day's work, proceeded to the market in El
Salvador, Misamis Oriental, to buy fish.

- Since no fish was available at that time, they decided to head for home instead. They went to the
national highway, stood at the right side facing east towards the direction of Cagayan de Oro City and
waited for a ride there.

- They flagged down an approaching passenger jeepney which, however, swerved dangerously towards
them. At this juncture, Rolando Manabat shouted at the jeep "Pesteng yawa-a kamo, Manligis man
kamo" (You devils, why did you try to run over us?).

- A passenger inside the jeepney shouted back "Noano man diay, isog mo?" (Why? Are you brave?).
- Immediately thereafter, two gunshots rang out in the air, accompanied by sparks coming from the
front right side of the jeepney. Then Rolando shouted, "Agay. I was shot." The vehicle did not stop but
instead speeded towards the direction of Cagayan de Oro City.

- Wounded on the right knee, Rolando was brought by his companions to the Cagayan de Oro Medical
Center. Later on, they were informed that Rolando needed blood transfusion and so they transferred
him at around 11:25 P.M. to the Northern Mindanao Regional Hospital in the same city.

- Upon arrival at the hospital, Rolando was examined by Dr. Ismael Naypa, Jr. The doctor found the
victim's blood pressure to be just forty over zero (40/0) and the victim's right leg was heavily bandaged.
He decided to operate on the victim when the latter's blood pressure stabilized. At about 5:00 A.M. the
following day, the victim underwent surgery.

- Unfortunately, the victim died at around 11:00 A.M. Dr. Naypa later testified that the cause of Rolando's
death was "secondary to huddle respiratory syndrome secondary to blood loss, secondary to gunshot
wounds", or briefly, massive loss of blood due to gunshot wound.

- He stated that under normal circumstances, the wound would not necessarily cause death but in this
case where the wound transected the major part of the leg, the wound was fatal.

- He clarified that the victim sustained only one gunshot wound which entered at the front portion of
the right knee and exited at the back of the right knee, causing two wounds.
- The El Salvador police conducted investigation on the incident. It was discovered that appellant Orlando
Acuram, a policeman assigned with the 421st PNP Company based at San Martin, Villanueva, Misamis
Oriental, was among the passengers of the errant jeepney. He was seated at the front, right side of the
jeepney and was the only one among its passengers who was carrying a firearm.

- Orlando Acuram was later surrendered by his commanding officer to the custody of the court on the
basis of the warrant of arrest issued by MCTC Judge Evelyn Nery. 7 On motion by the prosecution and
without objection from the defense, the trial court suspended appellant from the service and ordered
his detention at the provincial jail.
- During the trial, appellant admitted that he was on board the mentioned jeepney and had a gun at that
time but denied firing it. He claimed that it was impossible for him to fire his rifle during that time since
he was sitting at the front seat of the jeepney, sandwiched between the driver and the latter's father-
in-law. Moreover, he said that the rifle was locked and wrapped by his jacket and its barrel was even
pointed towards the driver.

- Appellant blames the death of the victim on the lack of prompt and proper medical attention given. He
insists that the delay in giving proper medical attendance to the victim constitutes an efficient
intervening cause which exempts him from criminal responsibility.

ISSUE:

- W/N the lack of prompt and proper medical attention given to Rolando Manabat can be considered an
efficient intervening cause.

RULING

- This assertion is disingenuous, to say the least.


- Appellant never introduced proof to support his allegation that the attending doctors in this case
were negligent in treating the victim.
- On the contrary, Dr. Ismael Naypa, Jr., testified that the attending doctor at the Cagayan de Oro
Medical Center tried his best in treating the victim by applying bandage on the injured leg to prevent
hemorrhage.
- He added that the victim was immediately given blood transfusion at the Northern Mindanao
Regional Hospital when the doctor found out that the victim had a very low blood pressure.
- Thereafter, the victim's blood pressure stabilized. Then, the doctor operated the victim as the main
blood vessel of the victim's right leg was cut, thereby causing massive loss of blood. The surgery was
finished in three hours. Unfortunately, the victim died hours later.
- We cannot hold the attending doctors liable for the death of the victim. The perceived delay in giving
medical treatment to the victim does not break at all the causal connection between the wrongful
act of the appellant and the injuries sustained by the victim. It does not constitute efficient
intervening cause.
- The proximate cause of the death of the deceased is the shooting by the appellant. It is settled that
anyone inflicting injuries is responsible for all the consequences of his criminal act such as death that
supervenes in consequence of the injuries.
- The fact that the injured did not receive proper medical attendance would not affect appellant's
criminal responsibility. The rule is founded on the practical policy of closing to the wrongdoer a
convenient avenue of escape from the just consequences of his wrongful act. If the rule were
otherwise, many criminals could avoid just accounting for their acts by merely establishing a doubt
as to the immediate cause of death.

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