b. Efficient Intervening Cause

Efficient Intervening Cause

Concept

An efficient intervening cause is a new, independent cause that breaks the natural and continuous connection between an offender’s felony and the resulting injury. It matters when determining whether the resulting injury is a consequence for which the offender is criminally liable. The mere fact that another event occurred after the felony does not make that event an efficient intervening cause. (Bataclan v. Medina, G.R. No. L-10126, 22 October 1957)

Governing provisions

Article 4 of the Revised Penal Code makes a person who commits a felony liable even though the wrongful act done is different from that which the person intended. The resulting harm must nevertheless be a natural and logical consequence of the felony; Article 4 does not dispense with causation. (Revised Penal Code, Article 4)

Requisites / Rules

• Identify the felony and the resulting injury. Ask whether the felony set in motion a natural and continuous sequence producing that injury. (Revised Penal Code, Article 4) (Bataclan v. Medina, G.R. No. L-10126, 22 October 1957)
• Identify the alleged intervening event. To sever liability for the resulting injury, it must operate as an independent cause that breaks the causal sequence—not merely occur between the felony and the injury. (Bataclan v. Medina, G.R. No. L-10126, 22 October 1957)
• Consider the whole sequence, including the victim’s response and any later acts. If the resulting injury still follows naturally from the danger created by the felony, an intervening event does not, by itself, erase the offender’s causal responsibility. (Revised Penal Code, Article 4) (Bataclan v. Medina, G.R. No. L-10126, 22 October 1957)

Distinctions

An efficient intervening cause is distinct from a contributing cause: the latter may help produce the injury without breaking the connection to the felony. It is also distinct from a mere lapse of time. The controlling question is whether the original felony remained a proximate cause of the injury, not whether it was the last event before the injury occurred. (Bataclan v. Medina, G.R. No. L-10126, 22 October 1957)

Key doctrines

In Bataclan v. Medina, the Court applied the proximate-cause test to a sequence involving an overturned bus, spilled gasoline, and a subsequent fire. The case illustrates why a later event must be examined in its setting: a later act or occurrence is not necessarily an independent cause when it develops from the danger already created. (Bataclan v. Medina, G.R. No. L-10126, 22 October 1957)

Bar tip

Do not answer solely by naming the last act before the injury. Trace the chain from the felony to the result, then explain whether the alleged intervening cause was independent enough to break it. (Revised Penal Code, Article 4) (Bataclan v. Medina, G.R. No. L-10126, 22 October 1957)