Criminal Law › The Revised Penal Code – Book One › Criminal Liability › Criminal Causation
a. Proximate Cause
2. Causes Affecting Criminal Liability
a. Proximate Cause b. Efficient Intervening Cause
Concurrent Negligence
Where the concurrent or successive negligent acts or omission of two or more persons, although acting independently of each other are, in combination, the direct and proximate cause of a single injury to a third person, and it is impossible to determine in what proportion each contributed to the injury, either is responsible for the whole injury, even though his act alone might not have caused the entire injury [PNCC v. CA, G.R. No. 159270 (2005)].
Felony committed must be the PROXIMATE CAUSE of the resulting injury
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, G.R. No. L-10126, 1957)
A person committing a felony is criminally liable for all the natural and logical consequences resulting therefrom although the wrongful act done be different from that which he intended. "Natural" refers to an occurrence in the ordinary course of human life or events, while "logical" means that there is a rational connection between the act of the accused and the resulting injury or damage.
The felony committed is NOT the proximate cause of the resulting injury when:
- An efficient intervening cause, independent of the felony, breaks the natural and continuous causal chain. An act by the victim must be assessed under this test and does not automatically break the chain.
If a person inflicts a wound with a deadly weapon in such a manner as to put life in jeopardy and death follows as a consequence of their felonious act, it does not alter its nature or diminish its criminality to prove that other causes cooperated in producing the factual result. 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. A different doctrine would tend to give immunity to crime and take away from human life a salutary and essential safeguard. (Quinto vs. Andres, G.R. No. 155791)
“Immediate”
Means “proximate”, unlike in sufficient provocation, and allows an interval of time between the commission of the offense and its vindication as long as the offender is still suffering from the mental agony brought about by the “offense” to him. (People v. Parana, G.R. No. 45373)
Authorities
- People v. Parana, G.R. No. 45373, 31 March 1937
- PNCC v. CA, G.R. No. 159270
- Quinto v. Andres, G.R. No. 155791, 16 March 2005
- Vda. De Bataclan v. Medina, G.R. No. L-10126, 22 October 1957