Digest – Art.

4 of RPC

People of the Philippines

vs.
Rolly Adriano y Samson, et. al
GR No. 205228

FACTS:
On March 13, 2007, at around 8 am, in Malapit, San Isidro, Nueva Ecija, a Toyota Corolla
overtook and shot a CRV car, causing it to swerve and fall in the canal embankment. Four armed men
then suddenly alighted the Corolla and started shooting at the driver of the CRV who was later identified
as Danilo Cabiedes. During the shooting, a bystander,Ofelia Bulanan, who was standing near the road
embankment, was hit by a stray bullet. Later, both Cabiedes and Bulanan died from fatal gunshot
wounds. During the investigation, police found out that such car was registered under the name Antonio
Rivera who happened to own a car rental business, and which car he leased to Adriano. Later that day,
Adriano arrived at Rivera’s shop with the Corolla and was immediately arrested after being identified by
police witnesses. After trial, the RTC convicted Adriano and was charged murder for the death of
Cabiedes, and homicide for the death of Bulanan.

ISSUE:
Whether or not Adriano is guilty for the death of Bulanan when her death was random and
unintentional and that the method used to kill her, as she was killed by a stray bullet, was by no mean,
deliberate.

RULING:

Yes. Supreme Court discussed the death of Bulanan who was merely a bystander and killed by a
stray bullet. Nonetheless, Adriano is guilty of the death under Article 4 of the RPC, pursuant to the
doctrine of aberration ictus, which imposes criminal liability for the acts committed in violation of law
and for all the natural and logical consequences resulting therefrom. Bulanan’s death caused by the
bullet fired by Adriano was the natural and direct consequence of Adriano’s felonious deadly assault
against Cabiedes.