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CANE - People v. Valdez

The accused threatened to kill the victim with a large knife on a ship in the Pasig River. Fearing for his life, the victim threw himself into the river and drowned. The accused argued he should only be liable for grave threats since he did not stab the victim, and drowning was a supervening cause of death. However, the court ruled the accused was liable for homicide because the victim acted solely out of self-preservation when jumping in the river, which was a reasonable response to the perceived threat. Proximate cause does not require actual contact - it is enough that the accused generated a sense of immediate danger in the victim's mind that caused him to endanger his own life.

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96 views1 page

CANE - People v. Valdez

The accused threatened to kill the victim with a large knife on a ship in the Pasig River. Fearing for his life, the victim threw himself into the river and drowned. The accused argued he should only be liable for grave threats since he did not stab the victim, and drowning was a supervening cause of death. However, the court ruled the accused was liable for homicide because the victim acted solely out of self-preservation when jumping in the river, which was a reasonable response to the perceived threat. Proximate cause does not require actual contact - it is enough that the accused generated a sense of immediate danger in the victim's mind that caused him to endanger his own life.

Uploaded by

Jerry Cane
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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THE UNITED STATES, 

plaintiff-appelle, vs.
CALIXTO VALDEZ Y QUIRI, defendant-appellant.
G.R. No. L-16486             March 22, 1921

Ponente: STREET, J.

FACTS:
The interisland steamer Vigan was anchored in the Pasig River. The accused shouted at the
offended party when he was slow in his work. The offended party replied that they would be
better if he would not insult them. The accused resented this, and rising in rage, he moved
towards the victim, with a big knife in hand threatening to kill him. The Victim believing
himself in great and immediate peril, threw himself into the water and disappeared beneath
its surface to be seen no more and possibly drowned. Venancio has not returned to his
lodging in Manila, where he lived as a bachelor in the house of an acquaintance; and his
personal belongings have been delivered to a representative of his mother who lives in the
Province of Iloilo. His friends and relatives, it is needless to say, take it for granted that he is
dead. The accused was prosecuted for homicide. His contention that his liability should be
only for grave threats since he did not even stab the victim, that the victim died of
drowning, and this can be considered as a supervening cause.

ISSUE:
Whether or not the accused is liable for homicide.

RULING:
The court affirmed the decision of the Trial Judge, with costs against the appellant. So
ordered.

RATIO,,,DECIDENDI:  
The deceased, in throwing himself into the river, acted solely in obedience to the instinct of
self-preservation, and was in no sense legally responsible for his own death. As to him, it
was but the exercise of a choice between two evils, and any reasonable person under the
same circumstance might have done the same.

This case illustrates that proximate cause does not require that the offender needs to
actually touch the body of the offended party. It is enough that the offender generated in
the mind of the offended party an immediate sense of danger that made him place his life at
risk. In this case, the accused must, therefore, be considered the author of the death of the
victim.

"If a man creates in another man's mind an immediate sense of dander which causes such
person to try to escape, and in so doing he injuries himself, the person who creates such a
state of mind is responsible for the injuries which result." (Reg. vs. Halliday, 61 L. T. Rep.
[N.S.], 701.)

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