Related Provisions:
US v BROBST
Criminal Liability: How Incurred
Date: October 25, 1909
Ponente: J. Carson
SUMMARY:
Brobst and Mann are owners of a mine. Mann fired
Saldivar, calling him a thief and was a disturbance and
warned him to never come back. A few days later,
Saldivar came back to the mine with 3 others looking for
employment. Upon seeing him, Brobst ordered him to
leave to which Saldivar merely grinned. Brobst struck
Saldivar with a powerful blow with his closed fist just
over the ribs. Saldivar left and died as he reached the
door to the house. The trial court held Brobst guilty of
homicide. Brobst appealed. SC upheld judgement of
conviction
ISSUES:
1. WoN Brobst is guilty of homicide even if there
was no intent to kill
2. WoN there was still doubt that the cause of
death of was the single blow of Brobst
FACTS:
1. Brobst and Mann engaged in work on a mine
and gave employment to the people of Masbate
2. Mann discharged Saldivar because he was a
thief and warned him never to set foot on the
premises again
3. July 10, 1907 – Saldivar, with 3 others, went to
the mine to look for work, was ordered to leave
by Brobst and was then struck with a blow
4. Saldivar staggered and went to the direction of
his sister’s house 200 yards away but died as he
reached the door to the house.
5. Brobst claims that he had a right to eject the
deceased from the mining property and that he
merely pushed lightly, as proved by the body
At the time or the case:
Penal Code
Art 1. Any person voluntarily
committing a crime or misdemeanor
shall incur criminal liability, even
though the wrongful act committed be
with no external marks of Violence. He had not different from that which he intended
intended to kill Saldivar and did not intend to do to commit.
him any physical injury.
6. Dagadap and Yotiga, bystanders at the time,
testified that the blow was indeed hard.
7. The trial court held Brobst guilty of homicide
and sentenced him to 6 years and 1 day of
prision mayor
8. Brobst appealed the decision
HOLDING:
1. Defendant asserts that he only exercised his
authority to eject the deceased. However, the
court ruled that his violence was far in excess of
such authority. Even if the accused did not
intend to kill, there can be no doubt that by
striking Saldivar, he intended to do him some
injury. One is not relieved from criminal liability
for the natural consequences of one's illegal
acts, merely because one does not intend to
produce such consequences.
2. The deceased was in apparent good health; after
receiving the blow immediately thereafter,
started up the short trail to his sister's house
and he died as he reach the door. "In the
absence of evidence of any intervening cause,
we think there can be no reasonable doubt that
his death resulted from the blow."
RULING:
Judgment of conviction by the trial court is affirmed.