People vs Luces

 Facts: 

Accused Ramon Luces gave a fist blow on the stomach of Feliciana, causing her to fall unconscious. She never regained consciousness and a few minutes thereafter she died. In the autopsy report, it was found that the probable cause ofdeath was cardiac failure. The accused contended that the fist blow was not the proximate cause of Feliciana's death. 

Held: 

Whether Feliciana died as a direct effect of the fist blow, or as an outcome of the fall that followed the blow, or as a consequence of the blow and the fall that caused her to lose consciousness, or of heart failure due to shock caused by the blow and her fall to the ground, the result would be the same — that the blow was the primary and proximate cause of her death. The gravity of the crime does not depend on the more or less violent means used, but on the result and consequence of the same and if the accused had not ill-treated the deceased she would not have died. Known is the Latin maxim that who is the cause of the cause, is the cause of the evil caused." 

Note: Ill-treating another by deed without causing any injury, is a felony under Art. 266 of this Code.