Case Digest: People vs. Adriano G.R. No. 205228, July 15, 2015

 
 
FACTS:
 
In March of 2007 in Nueva Ecija, Rolly Adriano, with his three others, overtook a policecar and a maroon Honda CRV. With intent to kill, treachery, and abuse of superior strength, willfully shot Danilo Cabiedes, the driver of CRV, resulting from his instant death.
 
The shooting incident caused a bystander, Ofelia Bulanan, to be hit by a stray bullet and eventually die.
Two policemen was able to trace the car used in the incident and ended up arresting Adriano. RTC found accused ROLLY ADRIANO guilty beyond reasonable doubt of Murder, as charged, for the death of Danilo Cabiedes, and also guilty beyond reasonable doubt of Homicide, as charged, for the death of Ofelia Bulanan.
 
CA affrimed the decision of RTC.
 
ISSUE:
 
Whether or not Adriano is responsible for the death of Ofelia Bulanan, a bystander.
 
RULING:
 
YES. Evidently, Adriano’s original intent was to kill Cabiedes. However, during the commission of the crime of murder, a stray bullet hit and killed Bulanan. Adriano is responsible for the consequences of his act of shooting Cabiedes. This is the import of 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 therefrom.  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 consequences of Adriano’s felonious deadly assault against Cabiedes.