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The Title IX of the Book II of then Spanish Penal Code (CP), has as title “Of the omission of the duty to help”. It is a title formed only by two articles, the article 195 and the article 196, being possible to regard the article 195 as the basic type and the 196 like the qualified when the omission to help is from a sanitary professional.
For trying to explain all the aspects concerning this title, we are going to divide this writing into three points: 1) The crime of omission of the duty to help; 2) The crime of the omission of the duty to help and the crime of imprudent homicide, y; 3) The crime of flight or fleeing and the crime of omission of the duty to impede a crime.
1) The crime of omission of the duty to help:
Article 195:
We should start commenting the basic type of the crime of omission of the duty to help, for this, the best will be to see first its content, for later explaining it.
“Article 195:
1. Who does not help a person who is helpless and is and in manifest and grave danger, when it could make it without a risk for itself or a third, will be punished with the punishment of fine from three to twelve months.
2. In the same punishment will incur who, being imped of helping, does not urgently demand alien help.
3. If the victim is for accident fortuitously occasioned by who omitted the help, the punishment will be of imprisonment from six to eighteen months, and if the accident is due for imprudence, of imprisonment from six to four months.”
As we can see, the article 195 is formed by three points. The first, is where we find the elements which compound the objective and subjective type of the crime, being, therefore, the most important. The typical behavior or the objective element of the type, consists in a malicious omission, not to help a helpless person and in manifest and grave danger, when it can be done without a risk to itself or others.
If we want to decompose the elements of the objective type, we will do it as follows: 1) A malicious omission of help; 2) Of a person who is helpless and in manifest and grave danger, and; 3) When this can be done without a risk for itself or others.
Consequently, in order to be able to talk about the existence of a crime, the three elements have to concur, for lacking any of them the behavior will be atypical or unpunishable.
Yet, we have to see another important part, we have not said anything of the subjective element of the type, although we have included it in the objective elements, for giving them more clarity. In the first of them, we said that it should be a malicious omission of help, this supposes, that the author of the crime should be conscious of the fact that with its omission it is putting into grave risk a person who is helpless, and besides, it is doing it, without being a risk for itself or others. To the above, the so-called direct malice, we should add the possibility that the crime could be committed through eventual malice, which will take place when the authors knows that with all probability its omission will give rise to the objective elements of the type, which we have already commented.
Let us see now, what is said by the Spanish courts, for traying to underpin what we have just seen. A good example, for how it explains the crime of omission of help, is the Provincial Courts of Merida´s resolution number 458/2022: “Starting with the basic figure of the crime of Omission of the duty to help, we have to point out that the kernel of the criminal action is in the omission of help to a person who is helpless and in grave and manifest danger, when it could do it without a risk for itself or others.
The reproach is elevated to the category of crime when the duties of solidarity are not fulfilled during determined situation, concrete and restricted, in other words, before an imminent and grave danger for a helpless person, who is affected by a situation which may put into risk its life; the omission of the duty of acting is reproachable, precisely, for the insensitivity before this situation which should be known, logically, by the author and notwithstanding this, it abstains from intervening being able to do it.
It constitutes a reproach separated from any relation with legal goods in danger, it is punished an unsupportive behavior, but concretized in the scenarios of manifest and grave danger for the life or physical integrity.”
And from the Spanish Supreme Court´s sentence number 3271/2022 we can obtain its requisites: “Indeed, the penal reproach for the infringement of the duty of assistance is subjected to demanding conditions of typification. First, that the person requesting the help should be in a situation of manifest and grave danger; second, it should be helpless; third, the obliged person should know this situation; fourth, it should have the capacity without a risk to itself or others, of personally giving help or requesting help to others.”
Among all these requisites, the one which has been more important in the practice, is the requisite that the victim should be in a situation of helplessness and in manifest or grave danger. The Spanish Supreme Court 3271/2022, says that: “the helplessness takes place when the person exposed to the grave and manifest danger lacks the necessary means for neutralizing or reducing it. Either because it cannot help itself or because it is not receiving alien help.”
Therefore, this situation will not take place, and the behavior will be regarded as atypical, when the person which is in a situation of helplessness and grave danger is being already assisted by another person, because precisely it will not be in this situation of helplessness anymore. The behavior will be atypical, even when who has caused the situation of helplessness, is not who help the victim, always that there is a person efficiently giving this help. The Provincial Court of Tenerife´s resolution number 481/2022 says regarding the above: “How is warned in the Spanish Supreme Court´s resolution 248/2021 of 30 March, without the existence of an objective situation of helplessness” the structure of the objective type collapses”, independently, even, of the fact that who omits does not adequately check it -in the same sense, in situations where is not possible to give objectively help for the immediate death of the person as consequence of the accident, Spanish Supreme Court´s sentences number 167/2022 of 24 February; 301/2022 of 24 March.”
Later, we are going to return upon our steps, for giving more information about this requisite, but first, in order to continue with the structure proposed by the article 195, we will comment the second of its points. As we have already seen, it says that the same punishments of the first point of the article 195 will be applied to the cases in which, who cannot help, does not urgently demand alien help. Evidently, it is referring to the cases in which someone is not capable of directly helping, but it can help asking for help to a third who does have this capacity, for example, by its medical knowledges. A good example, would be a person who is present during an a traffic accident and hastens to call an ambulance, it does not have the knowledges nor the means for helping, but those who it calls, do.
With the above, we pass to talk about the third point of the article 195. In it, is established a punishment more severe than the envisaged in the first point, prison instead of fine, for the cases in which the obliged to help, is the own person who has created this situation, irrespective of whether it has been fortuitously created or by imprudence. The first question we have to solve, is the difference which exists between something which may be regarded as fortuitous and something imprudent. For that, we are going to make use of the definition of imprudence.
The imprudence, is a complex legal concept, bordering with the eventual malice defined before when it is a grave imprudence, for the LO 1/2015 distinguishes between the grave imprudence and the less grave imprudence, being the slight imprudence reserved for the civil ambit of the non-contractual liability.
According to the Sentence of the Spanish Supreme Court 2648/2022: “the essence of the crime of imprudence is the infringement of the duty of care which makes reprochable this behavior because this care was demandable.” And down below it adds the elements of which it is made up: “a) A non-willful or malicious action or omission, with the absent of any direct or eventual malice; b) The psychological or subjective factor in the negligent acting for lacking of forecast of the risk, an element non-homogenisable and therefore susceptible of being appreciable in differing degree; c) the normative or objective factor represented by the infringement of the objective duty of care, specified in the regulation norms or imposed by the social and cultural norms demandable to ordinary citizen, according to common experience; d) production of the harmful result; and e) adequate causal relation between the careless behavior provoking the risk and the harm caused within the ambit of the objective imputation ( SSTS. 1382/2000 of 24.10, 1841/2000 of 1.12.).”
Now, we are going to return, to the explication of the requisite that the victim should be helpless and in manifest and grave danger. Here, we have to broaden the information given with respect this requisite, for as we can see, this third point of the article 195 imposes a special obligation of help upon who occasioned the situation for which a person is in a situation of helplessness and grave danger, because it imposes a severer punishment than the first point of the article 195, the punishment of imprisonment instead of fine. This scenario, will be especially relevant when the duty of help concurs in various persons, being one of them the one who provoked the situation of helplessness and grave danger, either fortuitously or by imprudence, since it will be upon it, upon which the obligation of help mainly applies. This obligation will end, when before the main obliged helps, another person provides this help, because it is algo obliged to provide it. Nevertheless, the obligation of helping only will be extinguished altogether, when the help provided by the third is efficacious, as much as, for making the help of the main obliged unnecessary.
We should mention again, the already mentioned Spanish Supreme Court´s sentence number 3271/2022, because it contains very interesting excerpts. It says: “6. It is true, as is suggested in the appeal, mentioning some precedents of this Chamber, that the helplessness does not disappear when the help given is insufficient. In normative terms, the helplessness penally relevant comprehends both the absolute – when the needed person does not receive any kind of help, and the relative – when what it receives is manifestly insufficient-. Nevertheless, in this case should be assessed if the residual danger, the one derived from the uncomplete help, is still grave, since otherwise the omission would continue being penally irrelevant for a lack of an essential requisite of typification.
7. We do not identify either, as is attempted in the appeal, as basis of the penal imputation requested, a kind of unfulfillment more intense and priority of the duty of help by the part of the accused. Upon this complex question of the concurring duties of actuation in help of whom is in a situation of grave and manifest danger, different resolutions of this Chamber have identified, with regard to the interpretation of the article 195.3 CP, a kind of priority duty of help but with respect to who has created the situation of danger.
In these cases, the simple presence of third persons who being even able to help does not make it effective does not exclude the penal relevance of the omission of the main obliged. As is affirmed in the Spanish Supreme Court´s sentence number 706/2012 of 24 September, with regard to an scenario in which various persons were present when the situation of grave and manifest danger arisen, “all had the obligation to help who needed it for being wounded on the floor after the hit, all those who were there took notice of the situation, without excusing the mere presence of some of them the duty of some others to help; but more than anyone was obliged to help who had been the cause of the accident. The interference of the convicted in the event which produced the injuries by virtue of a behavior gravelly negligent produces a duty of assistance to who is helpless and in manifest and grave danger, greater in intensity than the duty which have the other persons who, alien to the event, may had been there present knowing the situation of the victim.” In these cases, it is affirmed in the sentence, “the crime is consummated from the moment the person who caused the accident left the place of it when no one was helping the victim. That the help may arrive later cannot affect the reality of a crime which was already perfected.”
The reason for establishing priority duties and more intense of actuation in these cases resides in the necessity of guaranteeing the immediate object of protection -the legal goods of the person in danger- neutralizing the inhibitory effect of the fulfillment of the duty of help known as “non helping bystander effect” or “Genovese syndrome”- which paradoxically may be produced by the presence of various persons who observe the situation of danger.
Reliable psychological studies -Milgram, Amato, Levine- have demonstrated how, in these cases, increases the risk that no one starts helping until the rest make it, being generated an error in chain in the assessment of the danger derived from the situation. The passivity of some strengthens the passivity of the others, being produced a final effect of inattentiveness toward the person needed of help. Effect which increases when are present the persons obliged to help, as the causing of the situation of danger, for the thirds trust that those will fulfill with their duty of help.
But out of these cases in which the “inhibitory presence” of thirds does not exclude the typical relevance of the omission of whom has caused the situation of manifest and grave danger, in the general type of the article 195.1 CP, object of accusation, and as logical consequence, if there are various persons who alternatively and situationally result obliged, the duty of help ends when the needed person is already receiving assistance by another obliged and the hypothetical contribution of whom omits the duty does not provide nothing to the significant elimination or reduction of the situation of grave danger.
How is affirmed in the Spanish Supreme Court´s sentence number 482/2012 of 5 June the abstention of the duty results excusable “if, taking into account the circumstances, there already exists the duly help and the contribution of the third does not provide anything to the elimination of the situation of risk.” Something which happens with clarity in this case.
8. There is no doubt that the omissive behavior of the accused results especially reproachable in the ethic sphere, but it is not enough for convicting them for a crime of the article 195.1, as the appellants suggest. As we affirmed in the Spanish Supreme Court´s sentence 248/2021, of 30 March, without the existence of an objective situation of helplessness” the structure of the objective type collapses”, independently, even, of the fact that who omits does not adequately check it -in the same sense, in situations where is not possible to give objectively help for the immediate death of the person as consequence of the accident, Spanish Supreme Court´s sentences number 167/2022 of 24 February; 301/2022 of 24 March.”
Article 196:
The moment of talking of the article 196 has arrived. We said at the beginning that, in the article 196 we find the qualified type of the basic type of the article 195, since in it are imposed the punishments envisaged in the basic type, in its superior half.
The article 196 says:
“Article 196:
The professional who, being obliged to it, denies medical assistance or leaves the sanitary services, when from the denying or leaving is derived a grave risk for the health of the persons, will be punished with the punishments of the preceding article in its superior half and with the special disqualification for public job or charge, profession or trade, from six to three months.”
The objective type of the crime is constituted for: 1) The denying of assistance or leaving of the medical services, and; 2) When from the denying or leaving is derived a grave risk for the health of the persons.
As we can see, it is a specific omission of help, restricted to the sanitary ambit, being substituted the generic omission of help of the article 195, for the denying or leaving of the medical services.
We have to mention one more thing for completing this type. We should talk about its subjective elements. It is a malicious crime, at least in its eventual modality. This supposes that, the active subject should know that with its omission it is creating a grave risk for the health of the victim, or at least, it should know that probably its behavior is generating such risk.
Besides, in the active subject should concur a special quality. It should be a medical professional, what transforms it into an especial improper crime.
The Provincial Court of Merida´s sentence number 458/2022, although only referred to the denying of medical assistance, is interesting for how it helps us to delimit its scope: “This modality of the typical behavior consists in denying the adequate medical assistance before a situation of risk for the life, health or integrity, which may derive, if it is not attended, in a future infringement of such goods; and this denying comprehends both the mere passivity and the insufficient assistance always that it is requested in an express or tacit way.
Within the concept of “medical assistance” is included the necessary for the diagnosis and treatment of the illnesses and the conservation of the health carried out according to the rules of medical science; and comprehends also the behavior of the medical professional who, impeded of personally giving the adequate help (for lack of enough knowledges, means or another causes), does not require help or send the ill to another competent professional.”
2) The crime of omission of the duty to help and the crime of imprudent homicide:
With regard to this point, for the crime of omission of the duty to help we should understand, any of its two variables, the basic type of the article 195 and the qualified crime of the article 196. Let us analyze each of them separately.
Broadly speaking, the article 195 is formed by two cases: 1) To omit to help a person or ask for help, and; 2) When who has created the situation of grave risk and helplessness for the victim does not help it.
In the first scenario we said when we analyzed it that, It was essentially malicious, either in its direct or eventual modalities. This, from the beginning dismisses the possibility that any omission typified according to the article 195, could be regarded as imprudent homicide. Besides, the malices are different, whereas the malice of the article 195.1 consists in knowing that a person is in a situation of helplessness and grave danger and not helping, the malice of the crime of homicide (art. 138 CP) consists in wanting to kill a person. Therefore, even when the omission ends with the death of the victim who was in a situation of helplessness and grave danger, it cannot be regarded as a crime of homicide, not even for eventual malice, for in the active subject of the crime would have not been any will of killing it, it was only to omit to help (to look to another place), when the victim was in a grave situation.
On the other hand, the second scenario is not as clear as the above. In it, is punished who omits to help a person, having been who has created, either fortuitously or for imprudence, its situation of helplessness and grave danger. If the situation has been generated fortuitously, and the victim ends dying as consequence of this situation, the active subject who did not help the victim only could be punished according to the article 195.3, for in it does not concur any kind of guiltiness in the generation of the situation of risk, although it should have to respond for the direct or eventual malice of not helping the victim when it knew or thought that it was in a situation of helplessness and grave danger.
But, what happens if the situation of helplessness or grave danger was generated as consequence of the imprudence of the active subject and the victim ends dying? In this case, in my opinion, we are before a concurrence of crimes (art. 73 CP), but only if the imprudence which provoked the death could be regarded as grave, which should be solved punishing both behaviors separately. The same will happen if instead of the death of the victim, was provoked is any of the crimes of injuries envisaged in the CP (art. 147 and following).
Let us now talk of the article 196. As we have already seen, in it is punished the medical professional who denies the medical assistance or leaves the medical services, when it supposes a grave danger for the health of the persons. We have already seen that, it is a malicious crime, at least in its eventual modality, what requires that the medical professional knows that with the denying of the medical assistance or the leaving of the medical services it is creating a grave danger for the health of the person, or at least that it knows that probably it is happening. The article 196 says too that “it will be punished with the punishments of the above article”, its plural seems to refer to both kinds of punishments, fine and imprisonment, what indirectly comprehends the fortuitous and imprudent cases of the third point of the article 195, in other words, the cases in which the medical professional has fortuitously or by imprudence created, the grave situation for the health of the victim.
In this last scenario, like in the above, in my opinion, the medical professional could be accused of an imprudent homicide in a real concurrence of crimes with the crime of the article 196, when the denying or leaving of the medical services is accompanied of the death of the victim as consequence of a previous imprudence attributable to them.
3) The crime of flight or fleeing and the crime of omission of the duty to impede a crime:
In the CP there exist at least another two crimes which punish behaviors similar to the envisaged in the article 195 and 196. We are referring to the crime of flight or fleeing (art. 382 bis CP) and the crime of omission of the duty to impede a crime (art. 450 CP). It is not the place for deepening in their meaning, but we can see them, to know that they exist and what are their main characteristics.
The crime of flight or fleeing was introduced by the Organic Law 2/2019. In it is punished the driver of a motor vehicle or moped who, out of the cases established in the article 195, willfully and without concurring a risk for itself, leave the place of the facts after causing an accident in which have died one or various persons or is caused some crime of injuries. The article 386 bis says:
“Article 382 bis.
1. The driver of a motor vehicle or moped who, out of the cases contemplated in the article 195, willfully and without concurring a risk for itself of thirds, leaves the place of the facts after causing an accident in which have died one or various persons or in which have been caused any of the injuries to which are referred the articles 147.1, 149 and 150, will be punished as an author of a crime of leaving of the place of the accident.
2. The facts contemplated in this article which have their origin in an imprudent action of the driver, will be punished with the punishment of imprisonment from six months to four years and the privation of the right to drive motor vehicles and moped from one to four years.
3. If the origin of the facts which give rise to the leaving is fortuitous will correspond to it a punishment from three to six months of imprisonment and the privation of the right to drive motor vehicles and mopeds from six months to two years.”
It is special improper crime, since the active subject of it, can only be the driver of a motor vehicle or moped.
The objective type consists in: 1) Out of the cases contemplated in the article 195; 2) To leave willfully the place of the facts (after causing an accident); 3) Without a risk for itself or thirds, and; 4) When in the accident have died one or more persons or they have suffered punishable injuries.
That the facts cannot by typified according to the article 195, makes indifferent whether the requisite of being the victim into a situation of haplessness and grave danger is met, it makes punishable the facts even when the victim is being helped by a third and the help of the active subject, may be regarded as unnecessary, something which does not happen, as we have already seen, with the crime of omission of the duty to help.
With regard to the subjective elements of the type, it is a malicious crime, at least, in its eventual modality. This supposes that the active subject should know that it is leaving the place where it has provoked an accident, in which there have been mortal victims or punishable injuries, or at least, it has to think as probable this possibility.
The intention of the legislator is clear typifying this behavior, it is trying to avoid that who has caused an accident, even when it has been fortuitous or by imprudence, where there have been victims, flees from it, otherwise the victims would have really difficult to obtain the compensation that they deserve.
The Spanish Supreme Court´s sentence number 3271/2022 says regarding the above: “9. Conclusion which is strengthened if we take the reform of the CP by the Organic Law 2/2019, of 1 March, by means of which is introduced a new type in the article 382 bis CP whereby it is punished, “out of the cases contemplated in the article 195”, to who leaves after causing an accident, the place of the facts when it has provoked the death of one or more persons or injuries which constitute a crime of the article 152.2 CP. Type which is inspired in the art. 142 of the German Penal Code (StGB) which punishes the “crime of flight” or “crime of fleeing” as the answer to the infringer of a “legal duty to wait” and “assist”. Explicitly, the Exposition of Motives argues, as incriminating reason, the breaching of the duties of citizenship based in the value of solidarity, pretending with it “to cover cases of difficult fitting in the crime of omission of the duty to help for lacking the objective element of the existence of a helpless person and in manifest and grave danger (Spanish Supreme Court´s sentence number 167/2022 of 24 February).»
Lastly, we should talk of the crime of omission of the duty to impede a crime. It is a crime typified in the article 450, which says:
“Article 450.
1. Who, being able to do it with immediate intervention and without risk for itself or a third, does not impede the commission of a crime which affects to the persons in its life, integrity or health, freedom or sexual freedom, will be punished with the punishment of imprisonment from six months to two years if the crime was against the life, and of fine from six to twenty-four months in the rest of the cases, save when to the crime not impeded corresponds the same or less punishment, in whose case will be imposed the punishment inferior in degree to which it has assigned.
2. In the same punishments will incur who, being able to do it, does not go to the authorities or its agents for impeding a crime of the envisaged in the above point and of whose close or actual commission it has notice.”
It is a crime similar to the crime of omission of the duty to help, though adapted to the duty to impede a crime. The elements of its objective type are: 1) To be able to impede a crime with an immediate intervention and without risk to itself or a third, and; 2) It has to be a crime, which affects to the person in its life, integrity or health, freedom or sexual freedom.
Besides, the same punishments will be imposed, to who being able to make it, does not go to the authorities or its agents for impeding one of these crimes, which are being committed or will be committed soon.
With regard to the subjective elements of the type, it is a malicious crime, at least in its eventual modality. Thereby, the active subject should know that are being committed some of the crimes typified, or know that probably they are being committed, and despite this, not to intervene.
Here we are obliged to mention, the said by the Spanish Courts in relation to the crime of sexual aggression (art. 178 and following). According to repeated Spanish jurisprudence, those who are present during a sexual aggression should be regarded as necessary cooperators, even when they do not directly participate in the facts, it makes them authentic authors (art. 28 CP). In my opinion, this this would put us before a concurrence of norms, a crime of sexual aggression concurring along a crime of omission of the duty to impede a crime, which should be resolved by application of the fourth rule of the article 8, “In defect of the above criteria, the penal graver precept will exclude those which punish the fact with a minor punishment.”
Let us see the said by the Spanish Supreme Court ́s sentence number 534/2023: “Thus in the Spanish Supreme Court ́s sentence number 1142/2009 of 24 November, was pointed out that it was the same the preconceived plan than the group acts simultaneous to the act and not premeditated: “The figure of the necessary cooperation in the crimes of sexual aggression is contemplated in multiple sentences, for example the Spanish Supreme Court ́s sentence number 1291/2005 of 8 November says: “Ultimately, this concept of necessary cooperation is extended also to the cases in which, even not existing, a premeditated plan, is carried out the rape in the presence of persons without previous agreement, but with a conscience of the action committed. In these cases the intimidatory effect may be produced by the simple presence orconcurrence of various persons, different from who materially consummates the rape, since the existence of the group can produce in the victim an state of environmental intimidation.»
Later the same sentence continues: “In the same sense, the Spanish Supreme Court ́s sentence number 344/2019 of 4 July 2019, insists in delimiting the concept of environmental concept: “The Sentence number 1291/2005 of 8 November 2005, Rec. 263/2005, makes reference to the so-called “environmental intimidation”, where is stated that: “A conviction must punish all those who in a group participate in these cases of multiple sexual aggressions and because the presence of other or other persons who collude with who commits the forced sexual act forms part of the intimidating framework which weakens or even annuls the will of the victim for being able to resist, being, such presence coordinated in joint action with the main actor, integrating the figure of necessary cooperator of the point b) art. 28 CP. In these cases each is author of the number 1 of the art. 28 for the carnal act committed by it and necessary cooperator of the point b) of the same article, regarding the rest which its presence has favored (Spanish Supreme Court ́s sentences of 7 March 1997 and number 481/2004 of 7 April). Ultimately, this concept of necessary cooperation is extended also to the cases in which, even existing a premeditated plan, it is produced the rape in the presence of other persons, without previous agreement, but with conscience of the action committed by it. In these cases the intimidating effect may be the result of the simple presence or concurrence of various persons, different from who materially consummates the rape, since the existence of the group may create in the victim a state of environmental intimidation.”
Later, it explains why those present during a sexual aggression have to be regarded as necessary cooperators and not like accomplices: “On the other hand, this Chamber has also repeatedly declared that the complicity is distinguished from the necessary cooperation in the secondary character of the intervention, without which the criminal action might have been committed too, for not being its contribution of necessary character, either in the own sense, or in the sense of being easily substitutable for not being a scarce good. The complicity requires a participation merely accessory, not essential, which has been interpreted in terms of concrete dispensability or related with the case tried, not in terms of hypothetical committing circumstances, there should exist between the behavior of the accomplice and the execution of the infringement a contribution which although is not necessary, facilitates the commission of the crime by the main author (Spanish Supreme Court ́s sentences number 676/2002, of 7 May; 1216/2002 of 28 June; 185/2005 of 21 February; 94/2006 of 10 January; 16/2009 of 27 January; 109/2012 of 14 February; and 165/2016 of 2 March).
Hence, how is repeated by the Spanish Supreme Court the contribution to the rape creating the violence or environmental intimidation is essential and not accessory, it constitutes a scarce good of difficult obtaining and besides it contributes to the execution of the result.”
Víctor López Camacho.
Twitter: @victorsuperlope.
More on my website: www.victorlopezcamacho.com