The doctrine of proximate cause

Proximate cause is that cause which in natural and continuous sequence, unbroken by an efficient intervening cause, produces the injury, and without which, the result would not have occurred.

The proximate legal cause is that acting first and producing the injury, either immediately or by setting other events in motion, all constituting chain of events, each having a close causal connection with its immediate predecessor. There must be a relation of "cause and effect," the cause being the felonious act of the offender, the effect of being the resultant injuries and/or death of the victim.

The "cause and effect" relationship is not altered or changed because of the pre-existing conditions, such as the pathological condition of the victim; the predisposition of the offended party; the physical condition of the offended party; or the concomitant or concurrent conditions, such as the negligence or fault of the doctors; or the conditions supervising the felonious act such as tetanus, pulmonary infection or gangrene. If a person inflicts a wound with a deadly weapon in such 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 delightful act caused, accelerated or contributed to the death of the victim. A different doctrine would tend to give immunity to crime and to take away from human life a salutary an essential safeguard. (Quinto vs. Andres, G.R. 155791, March 16, 2005).

May we discuss the case related to this:

Melba Quinto v. Dante Andres, G. R. No. 15591, March 16, 2005

The eleven-year-old Edison Garcia, a Grade 4 elementary school pupil, and his playmate, Wilson Quinto, who was about eleven years old, were at Barangay San Rafael, Tarlac, Tarlac, at around 7:30 a.m. on November 13, 1995.

They saw respondents Dante Andres and Randyver Pacheco by the mouth of a drainage culvert. Andres and Pacheco invited Wilson to go fishing with them inside the drainage culvert to which Wilson agreed to. However, when Garcia saw that it was dark inside, he opted to remain seated in the grassy area about two meters from the entrance of the drainage system. Respondent Pacheco had a flashlight. He, along with Wilson and respondent Andres, entered the drainage system which was covered by concrete culvert about a meter high and a meter wide, with water about a foot deep. After a while, respondent Pacheco, who was holding a fish, came out of the drainage system without saying a word. Respondent Andres came out, went back inside, and emerged again, this time carrying Wilson who was already dead. 

Respondent Andres laid the boy's lifeless body down in the grassy area. Shocked at the sudden turn of events, Garcia fled from the scene. 

For his part, Andres went to the house of the petitioner Melba Quinto, Wilson's mother, and informed her that her that her son Wilson died. Melba rushed to the drainage culvert while respondent Andres followed her.

In a post-mortem examination, the cause of death was: Asphyxia by drowning; traumatic head injuries, contributory.

Issues:
a.) Whether or not the extinction of respondent's criminal liability, likewise, carries with it the extinction of their civil liability.
b.) Whether or not the preponderant evidence exists to hold the respondents to be civilly liable for the death of Wilson Quinto.

Ruling: 
Every person criminally liable for a felony is civilly liable. A person committing a felony is criminally liable for all the natural and logical consequences resulting therefrom although the wrongful act that was done be different from that which he intended.

The felony committed must be the proximate cause of the resulting injury.

If a person inflicts a wound with a deadly weapon in such 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.

In the present case, the respondents were charged with homicide by dolo (deceit). 

The Supreme Court ruled that, as held by the trial court and the CA, the prosecution failed to adduce preponderant evidence to prove the facts on which the civil liability of the respondents rest, i.e., that the petitioner has a cause of action against the respondents for damages.

He presented two possibilities:
1. That the deceased could have been hit by a blunt object or instrument applied with full force, or
2. The deceased could have slipped, fell hard and his head hit a hard object.
The trial court gave credence to the testimony of Dr. Aguda that the deceased might have slipped, causing the latter to fall hard and have his head hit on the pavement.
However, the absence of any ill-motive to kill the deceased is relevant and admissible in evidence to prove that no violence was perpetrated on the person of the deceased.

In this case, the petitioner failed to adduce the proof of any ill-motive on the part of either respondent to kill the deceased before or after the latter was invited to join them in fishing. Indeed, the petitioner testified that respondent Andres used to go to their house and play with her son before the latter's death.

Principles:
the prime purpose of the criminal action is to punish the offender in order to deter him and others from committing the same or similar offense, to isolate him from society, to reform and rehabilitate him, or in general, to maintain social order.

The sole purpose of a civil action is restitution, reparation or indemnification of the private offended party for the damage or injury he sustained by reason of the delictual or felonious act of the accused.

"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 proximate cause is that cause which in natural and continuous sequence, unbroken by an efficient intervening cause, produces the injury, and without which, the result would not have occurred.

There must be a relation of "cause and effect," the cause being the felonious act of the offender, and the effect being the resultant injuries and/or death of the victim.

References:
Supreme Court Decisions in Criminal law
http:judiciary.gov.ph
lawyerly.com