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People Vs Martin - Crim

Aniceto Martin was found guilty of killing his wife Laura Liz. Martin admitted to strangling his wife with rope after they had argued about their problematic marriage. Her body was discovered in the family toilet with rope marks around her neck. Martin claimed her death was due to a preexisting heart condition, not the strangling. However, the court ruled the strangling was the proximate cause of death, as it likely caused fright or shock that exacerbated her heart condition. Under Philippine law, one is responsible for criminal consequences even if the victim had a preexisting medical condition, so long as the illegal act was the proximate cause of death. Martin was found guilty.

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John Braynel Pural
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235 views2 pages

People Vs Martin - Crim

Aniceto Martin was found guilty of killing his wife Laura Liz. Martin admitted to strangling his wife with rope after they had argued about their problematic marriage. Her body was discovered in the family toilet with rope marks around her neck. Martin claimed her death was due to a preexisting heart condition, not the strangling. However, the court ruled the strangling was the proximate cause of death, as it likely caused fright or shock that exacerbated her heart condition. Under Philippine law, one is responsible for criminal consequences even if the victim had a preexisting medical condition, so long as the illegal act was the proximate cause of death. Martin was found guilty.

Uploaded by

John Braynel Pural
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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By: Braynel Pural

G.R. No. L-3002 May 23, 1951


THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee,
vs.
ANICETO MARTIN, defendant-appellant.
Ponente: Jugo, J.
Topic: Proximate cause
Facts:
Aniceto Martin, twenty-eight years old, a farmer, was living in the barrio No. 12 of the
municipality of Laoag, Ilocos Norte. He courted the girl Laura Liz of the same barrio for several
months and was accepted. They had sexual intercourse before marriage and she became
pregnant. In an advanced stage of pregnancy, she came to live with the family of the family of
the defendant and demanded marriage, which was duly solemnized on June 7, 1948, and they
continued to live as husband and wife.
On August 1, 1948, between 4 and 5 o’clock in the morning , the corpse of Laura was
found inside the family toilet, which was a at a certain distance from their home. Her body was
found with maguey rope around her neck leaving a circular mark around it with the exception of
the nape which was unmarked probably due to her long thick hair. The corpse was found by
Anselma Martin, sister of the accused, who was living in the same hous, and Saturnino
Tumaneng, brother-in- law of Laura.
The same day, Martin was found by his relatives near a farm, and promised to make a
statement in the municipal building. He then admitted killing his wife. But according to him, her
wife had tried to strange him with the rope while he was in the toilet. Prior to that incident, they
had first quarreled over their problematic marital relationship. He told her that he did not love
her, and their marriage was only a result of his fear of being a subject of court action against him.
Upon strangling her wife with the rope, he claimed that he was not doing it to kill her but
just to do the same thing she was trying to do him which was to strangle him with a rope. He
now contends that the death of Laura was not due to the strangling, but to her heart disease.
Issue:
Whether or not Martin’s act of strangling his wife is the proximate cause of her death?
Ruling:

Yes. It should be noted, however that the heart failure was due to the fright or shock caused by
the strangling, and consequently, the defendant was responsible for the death, notwithstanding
the fact that the victim was already sick. Had not the defendant strangled the deceased, the latter,
notwithstanding her illness, would not have died. In other words, the defendant directly caused
her death.
In the case of People vs. Reyes (61 Phil. 341, 343,) the Court held:

. . . A person is responsible for the consequences of his criminal act and even if the
deceased had been shown to be suffering from a diseased heart (which was not shown),
appellants assault being the proximate cause of the death, he would be responsible.
(U.S. vs. Luciano, 2 Phil., 96; U.S. vs. Lugo & Lugo, 8 Phil., 80; U.S. vs. Brobst, 14 Phil.
310; U.S. vs. Rodriguez, 23 Phil 22.)

In the case of U.S. vs. Brobst (14 Phil. 310), the following doctrine was established:

Where death results as the direct consequences of the use of illegal violence, the mere
fact that the diseased or weakened condition of the injured person contributed to his
death, does not relieve the illegal aggressor of criminal responsibility.

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