People of The Philippines vs. Rolly Adriano Et Al.

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People of The Philippines vs. Rolly Adriano Et Al.

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Irvinzor Gallardo

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G.R. No.

205228 July 15, 2015

People of the Philippines
vs.
Rolly Adriano et al.

FACTS:
On 13 March 2007, PO 1 Matthew Garabiles and P02 Alejandro Santos, in civilian clothes, were
on their way to Camp Olivas, Pampanga, riding a motorcycle along Olongapo-Gapan National Road.
While they were at Barangay Malapit San Isidro, Nueva Ecija, a speeding blue Toyota Corolla with plate
no. WHK 635, heading towards the same direction, overtook them and the car in front of them, a maroon
Honda CRV with plate no. CTL 957. When the Corolla reached alongside the CRV, the passenger on the
front seat of the Corolla shot the CRV and caused the CRV to swerve and fall in the canal in the road
embankment. Four (4) armed men then suddenly alighted the Corolla and started shooting at the driver of
the CRV, who was later identified as Cabiedes. During the shooting, a bystander, Bulanan, who was
standing near the road embankment, was hit by a stray bullet. The four-armed men hurried back to the
Corolla and immediately left the crime scene. PO 1 Garabiles and P02 Santos followed the Corolla but
lost track of the latter. Later, both Cabiedes and Bulanan died from fatal gunshot wounds. During the
investigation, the police learned that the Corolla was registered under the name of Antonio V. Rivera.
Upon inquiry, Rivera admitted that he is the owner of the Corolla but clarified that the Corolla is one of
the several cars he owns in his car rental business, which he leased to Adriano. RTC convicted Adriano
guilty beyond reasonable doubt of Murder, for the death of Danilo Cabiedes, and guilty beyond
reasonable doubt of Homicide, for the death of Ofelia Bulanan. The Court of Appeals affirmed the ruling
of the RTC.

ISSUE:
WON. Rolly Adriano is responsible for the death of Ofelia Bulanan.

RULING:
YES. Under Article 4 of the Revised Penal Code, pursuant to the doctrine of aberratio ictus,
which imposes criminal liability for the acts committed in violation of law and for all the natural and
logical consequences resulting there from. While it may not have been Adriano's intention to shoot
Bulanan, this fact will not exculpate him. Bulanan' s death caused by the bullet fired by Adriano was the
natural and direct consequence of Adriano's felonious deadly assault against Cabiedes. As held in People
v. Herrera citing People v. Ural: Criminal liability is incurred by any person committing a felony although
the wrongful act be different from that which is intended. The rationale of the rule is found in the
doctrine, 'El que es causa de la causa es causa del mal causado ', or he who is the cause of the cause is the
cause of the evil caused.