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People v. Ortega (276 SCRA 166)

Benjamin Ortega Jr. and Manuel Garcia were charged with murder for killing Andre Man Masangkay. Witnesses saw Ortega stab Masangkay with a long blade then he and Garcia dropped Masangkay's body into a well and placed stones on top, drowning him. The court found them guilty of murder, even though Masangkay died from drowning not the stab wounds. The Supreme Court upheld the conviction, finding that a person who commits a felony is criminally liable for unintended consequences of their wrongful act, like a more serious resulting crime, if the unintended act was primarily caused by the defendant's wrongful conduct.

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476 views1 page

People v. Ortega (276 SCRA 166)

Benjamin Ortega Jr. and Manuel Garcia were charged with murder for killing Andre Man Masangkay. Witnesses saw Ortega stab Masangkay with a long blade then he and Garcia dropped Masangkay's body into a well and placed stones on top, drowning him. The court found them guilty of murder, even though Masangkay died from drowning not the stab wounds. The Supreme Court upheld the conviction, finding that a person who commits a felony is criminally liable for unintended consequences of their wrongful act, like a more serious resulting crime, if the unintended act was primarily caused by the defendant's wrongful conduct.

Uploaded by

tink echivere
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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People v.

Ortega (276 SCRA 166)


Facts :
In 1992, Benjamin Ortega, Jr., Manuel Garcia and a certain John Doe were changed with
murder for the killing Andre Man Masangkay. As narrated by a witness, the victim
answered the called of nature and went to the back portion of the house where they were
having a drinking spree.
Accused Ortega followed him and later they heard the victim shouting for help and when
they ran towards the scene he saw the accused on top of the victim and stabbing the
latter with a long bladed weapon. Thereafter, Ortega and Garcia brought the victim to a
well and dropped him and placed stones into the well.
The trial court found the accused guilty beyond reasonable doubt. The accused appealed
averring that the trial court erred in holding them criminally liable because at the time the
victim was dropped into the well, he was still alive.
Issue:
Whether or not the accused may be held criminally liable for the death of the victim which
is not attributable to the stab wounds but due to drowning?
Decision:
A person who commits a felony is criminally liable for the direct natural and logical
consequences of his wrongful act even where the resulting crime is more serious than
that intended.
The essential requisites for this criminal liability to attach are as follows :
1. the intended act is felonious ;
2. the resulting act is likewise a felony; and3. the unintended graven wrong was primarily
caused by the actor’s wrongful acts.

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