US v. Valdez (G.R. No. L-16486. Mar. 22, 1921)
CASE DIGEST: [G.R. No. L-16486. March 22, 1921] THE UNITED STATES, plaintiff-appelle, vs. CALIXTO VALDEZ Y QUIRI, defendant-appellant. STREET, J.:
FACTS: The deceased is a member of the crew of a vessel. Accused is in charge of the crew members engaged in the loading of cargo in the vessel.
Because the offended party was slow in his work, the accused shouted at him. The offended party replied that they would be better if he would not insult them.
The accused resented this, and rising in rage, he moved towards the victim, with a big knife in hand threatening to kill him.
The victim believing himself to be in immediate peril threw himself into the water. The victim died of drowning. The accused was prosecuted for homicide. His contention that his liability should be only for grave threats since he did not even stab the victim, that the victim died of drowning, and this can be considered as a supervening cause.
HELD: The deceased, in throwing himself into the river, acted solely in obedience to the instinct of self-preservation, and was in no sense legally responsible for his own death. As to him, it was but the exercise of a choice between two evils, and any reasonable person under the same circumstance might have done the same.
This case illustrates that proximate cause does not require that the offender needs to actually touch the body of the offended party.
It is enough that the offender generated in the mind of the offended party an immediate sense of danger that made him place his life at risk. In this case, the accused must, therefore, be considered the author of the death of the victim.
"If a man creates in another man's mind an immediate sense of dander which causes such person to try to escape, and in so doing he injuries himself, the person who creates such a state of mind is responsible for the injuries which result." (Reg. vs. Halliday, 61 L. T. Rep. [N.S.], 701.)
FACTS: The deceased is a member of the crew of a vessel. Accused is in charge of the crew members engaged in the loading of cargo in the vessel.
Because the offended party was slow in his work, the accused shouted at him. The offended party replied that they would be better if he would not insult them.
The accused resented this, and rising in rage, he moved towards the victim, with a big knife in hand threatening to kill him.
The victim believing himself to be in immediate peril threw himself into the water. The victim died of drowning. The accused was prosecuted for homicide. His contention that his liability should be only for grave threats since he did not even stab the victim, that the victim died of drowning, and this can be considered as a supervening cause.
HELD: The deceased, in throwing himself into the river, acted solely in obedience to the instinct of self-preservation, and was in no sense legally responsible for his own death. As to him, it was but the exercise of a choice between two evils, and any reasonable person under the same circumstance might have done the same.
This case illustrates that proximate cause does not require that the offender needs to actually touch the body of the offended party.
It is enough that the offender generated in the mind of the offended party an immediate sense of danger that made him place his life at risk. In this case, the accused must, therefore, be considered the author of the death of the victim.
"If a man creates in another man's mind an immediate sense of dander which causes such person to try to escape, and in so doing he injuries himself, the person who creates such a state of mind is responsible for the injuries which result." (Reg. vs. Halliday, 61 L. T. Rep. [N.S.], 701.)
