People vs. Monleon

People vs. Monleon

December 10, 1946 (74 SCRA 263)

PARTIES:
plaintiff-appellee: People of the Philippines
accused- appellant: Cosme Monleon

FACTS:
On June 1, 1970, Cosme Monleon in his inebriated state asked whether the carabao was already fed. To check the veracity of the statement, he went to see the carabao. He discovered that the carabao had not been adequately fed. He was about to hit Marciano, his 10 year old son, when Concordia, his wife, intervened. Monleon choked her, bashed her head against the post, and kicked her abdomen. Concordia died the following day due to trauma or external violence.

ISSUE:
WON the accused is criminally liable although he had no intention to kill his wife.

HELD:
Yes. Art 4 of the Revised Penal Code provides that criminal liability is incurred by any person committing a felony although the wrongful act don be different than that which he intended to do. The maltreatment inflicted by the accused on his wife was the proximate cause of her death. He could have easily killed his wife had he really intended to take her life. He did not kill her outright. The accused was found guilty of parricide sentencing him to reclusion perpetua.

The Supreme Court applied Article 5 of the Revised Penal Code, "considering that the accused had no intent to kill his wife and that her death might have been hastened by lack of appropriate medical attendance or her weak constitution." The penalty of reclusion perpetua, prescribed by law for the crime committed, appears to be excessive.

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