FACTS

ISSUE

RULING

PP vs OANIS

W/ON Oanis and company incur no criminal liability based on the

contention of Mistake of Fact?

under the circumstances of the case, the crime committed by appellants is murder through specially mitigated
by circumstances

found guilty by the lower court of homicide through reckless imprudence

Information received escaped convict AnselmoBalagtas with

bailarinaand Irene in Cabanatuan get him dead or alive
Respondent group arrived at Irene's house, Oanis approached one
BrigidaMallare
Brigida indicated the place and upon further inquiry also said that Irene
was sleeping with her paramour.
seeing a man sleeping with his back towards the door where they were,
simultaneously or successively fired at him with their .32 and .45 caliber
revolvers
the person shot and killed was not the notorious criminal
AnselmoBalagtas but a peaceful and innocent citizen named
SerapioTecson, Irene's paramour
contended that they acted in innocent mistake of fact in the honest
performance of their official duties, both of them believing that Tecson
was Balagtas, they incur no criminal liability

The maxim is ignorantiafactiexcusat, but this applies only when the mistake is committed without
fault or carelessness.
found no circumstances whatsoever which would press them to immediate action. The person in
the room being then asleep, appellants had ample time and opportunity to ascertain his identity
without hazard to themselves, and could even effect a bloodless arrest if any reasonable effort to
that end had been made
a peace officer cannot claim exemption from criminal liability if he uses unnecessary force or
violence in making an arrest
The crime committed by appellants is not merely criminal negligence, the killing being intentional
and not accidental
Mitigating circumstance of acts in the fulfillment of a duty or in the lawful exercise of a right or
office

US vsAchong
guilty by the trial court of simple homicide, with extenuating circumstances

defendant, Ah Chong, was employed as a cook at "Officers' quarters,

No. 27," Fort McKinley, Rizal Province
at the same place PascualGualberto, deceased, was employed as a
house boy or muchacho.
thedefendantwas suddenly awakened by some trying to force open the
door of the room.
called out twice, "Who is there?" He heard no answer
fearing that the intruder was a robber or a thief, leaped to his feet and
called out. "If you enter the room, I will kill you."
hestabbed his roommate, Pascualunder the impression that he was "a
ladron" because he forced open the door of their sleeping room,
despite defendant's warnings.
Defendants contention that he struck the fatal blow without any intent
to do a wrongful act, in the exercise of his lawful right of self-defense.

W/ON Achong can be held criminally responsible by reason of a

mistake as to the facts for which he would be exempt from criminal
liability?

under such circumstances there is no criminal liability, the alleged ignorance or mistake or fact was not due to
negligence or bad faith. defendant acquitted of the crime with which he is charged

ignorance or mistake of fact, if such ignorance or mistake of fact is sufficient to negative a

particular intent

the Penal Code deemed criminal intent or malice to be an essential element of the various crimes
and misdemeanors

as Actus non facitreum nisi mens sit rea, "the act itself does not make man guilty unless his
intention were so

Actus me incitofactus non estmeusactus, "an act done by me against my will is not my act;"

evil intent is in general an inseparable element in every crime, any such mistake of fact as shows
the act committed to have proceeded from no sort of evil in the mind necessarily relieves the actor

from criminal liability provided always there is no fault or negligence on his part

proof of his innocent mistake of the facts overcomes the presumption of malice or criminal intent

the defendant at the time, he acted in good faith, without malice, or criminal intent, in the belief
that he was doing no more than exercising his legitimate right of self-defense

FACTS

ISSUE

RULING

W/ON the accused is guilty of the crime of Arson?

The fact of setting fire to a jute sack and a rag, soaked with kerosene oil and placed beside an upright of the
house and a partition of the entresol of the building, thus endangering the burning of the latter, constitutes the
crime of frustrated arson of an inhabited house

US vs Valdez
Court of First Instance charged accused of the crime of arson

Mrs. Auckback, who appears to have been a resident of the

neighborhood, called Mrs. Lewin and told her that much smoke was
issuing from the lower floor of the latter's house,
A kerosene oil placed between a post of the house and a partition of
the entresol, a piece of a jute sack and a rag which were burning. At
that moment the defendant Valdes was in the entresol,
dismissed with respect to the other defendant Hugo Labarro, for lack of
evidence
Owing to the repeated attempts made for about a month past, since
Severino Valdes Began to serve the Lewin family, to burn the house
above mentioned

The crime provided for is punished by article 549, in connection with articles 3, paragraph 2, and
65 of the Penal Code, and the sole proven perpetrator of the same by direct participation is the
defendant Severino Valdes
frustrated arson, inasmuch as the defendant performed all the acts conceive to the burning of said
house, but nevertheless., owing to causes independent of his will, the criminal act which he
intended was not produced
the partition might have started to burn, had the fire not been put out on time

PP vs Wong Cheng
the appellee is accused of having illegally smoked opium, was dismissed by the
lower court for lack of jurisdiction

W/ON the courts of the Philippines have jurisdiction over crime of

smoking opium committed aboard merchant vessels anchored in

to smoke opium within our territorial limits, even though aboard a foreign merchant ship, is certainly a breach

illegally smoked opium, aboard the merchant vessel Changsa of

English nationality while said vessel was anchored in Manila Bay two
and a half miles from the shores of the city.

our jurisdiction waters?

of the public order

the English rule, crimes perpetrated under such circumstances are in general triable in the courts
of the country within territory they were committed

PP vsAlmonte
convicted of the crime of homicide by the trial court

Defendant lived martially with Felix Te Sue, and with the threat of
Miguela to bring suit against him, he separated with the defendant
Visiting Felix Te Sue, defendant found him with Miguela, thus Felix told
her to go away
feeling that she was being unjustly treated, took hold of a small
penknife she carried and stabbed the man in the abdomen
Felix was given first aid with a minor operation. It was not serious,
according to the doctor, and might be healed in a week; but on the sixth
day the patient succumbed to complications and died

FACTS

W/ON the accused is responsible for the death of the offended

party as the direct and immediate consequence of the wound
inflicted by the accused.

ISSUE

PP vsToling
Court of First Instance of Laguna, finding defendant brothers guilty of multiple
murder and attempted murder, sentencing them to death

W/ON Accused be held responsible for the rampage killing

occurring in the train?

Antonio Toling and Jose Toling, twins, are illiterate farmers tilling their
own lands
Both of them travel to Manila to visit Antonios daughter and went back
home aboard a train
Inside the train, the twins' was in rampageous behavior, which resulted
in the macabre deaths of several innocent persons

the victim Andre Mar Masangkay, Ariel Caranto, Romeo Ortega,

Where a person voluntarily and with intent of injuring another commits an act which is notoriously
unlawful, he shall be held responsible for the consequences of his criminal action, even though
when such wrongful act constitutes the crime of homicide it appears that he had no intention of
killing the deceased."

RULING

The eight killings and the attempted killing should be treated as separate crimes of murder and attempted
murder qualified be treachery

PP vs Ortega
Found guilty by trial court of treachery and evident premeditation and with abuse
of superior strenght (sic) and with deliberate intent to kill,

the real cause of death in this case was not the bodily movements referred to, but the congestion of the
internal veins produced beforehand by the force of the blow which caused the wound and the nervous
condition of the deceased

The defense failed to prove that persons, other than the twins, could have inflicted the stab
wounds. There is no doubt as to the corpus delicti.
no doubt that the twins, from their own admissions and their testimonies, not to mention the
testimonies of Rayel, Aldea, Mrs. Mapa and the CIS investigators, were the authors of the killings.
they were caught in flagrante delicto
The rule is that "if a man creates in another man's mind an immediate sense of danger which
causes such person to try to escape, and in so doing he injures himself, the person who creates
such a state of mind is responsible for the injuries which result"

Appellant Ortega is guilty only of homicide. Appellant Garcia deserves acquittal

W/ON Ortega is guilty of the crime Homicide?

Nothing in the foregoing testimony and circumstances can be interpreted as abuse of superior
strength. Hence, Ortega is liable only for homicide, not murder
the prosecution evidence shows Masangkay was already dead when he was lifted and dumped

Roberto San Andres were having a drinking spree in the compound

near the house of Benjamin Ortega, Jr
heard the victim Andre Mar shouted, Dont, help meand found accused
Benjamin Ortega, Jr., on top of Andre Mar Masangkay who was lying
down in a canal with his face up and stabbing the latter with a long
bladed weapon
Romeo Ortega went to the place of the stabbing and together with
Benjamin Ortega, Jr. and Manuel Garcia lifted Andre Mar Masangkay
from the canal and brought Andre Mar to the well and dropped the
latter inside the well.
the lifeless body was pulled out from the well. That the body has
several stab wounds

into the well. Hence, Garcia could be held liable only as an accessory. [29]
The drowning was the direct, natural and logical consequence of the felony that Appellant Garcia
had intended to commit; it exemplifies praeterintentionem covered by Article 4, par. 1, of the
Revised Penal Code. Under this paragraph, a person may be convicted of homicide although he
had no original intent to kill
Appellant Garcia cannot be convicted of homicide through drowning in an information that charges
murder by means of stabbing (not alleged in the information)

FACTS

ISSUE

RULING

Urbano vs IAC

W/ON there was an efficient intervening cause from the time Javier
was wounded until his death which would acquit Urbano from any
liability for Javier's death?

the infection of the wound by tetanus was an efficient intervening cause later or between the time Javier was
wounded to the time of his death. The infection was, therefore, distinct and foreign to the crime. The
petitioner is ACQUITTED of the crime of homicide

Found by trial court of guilty beyond reasonable doubt of the crime of homicide

petitioner FilomenoUrbano went to his ricefield, He found the place

where he stored his palay flooded with water coming from the irrigation
canal nearby
Urbano then got angry and demanded that Javier pay for his soaked
palay. A quarrel between them ensued. Urbano unsheathed his bolo
and hacked Javier hitting him on the right palm of his hand
Javier was treated by Dr. Meneses, Urbano and Javier agreed to settle
their differences. Urbano promised to pay P700.00 for the medical
expenses of Javier
After 22 days, Javier was rushed to the Nazareth General Hospital in a
very serious condition, caused by tetanus toxin, he suffered the
symptoms of tetanus, like lockjaw and muscle spasms. The following
day, he died
Urbano was charged with the crime of homicide

at the time Javier's wound was inflicted by the appellant, the severe form of tetanus that killed him
was not yet present. Consequently, Javier's wound could have been infected with tetanus after the
hacking incident.
The rule is that the death of the victim must be the direct, natural, and logical consequence of the
wounds inflicted upon him by the accused.

PP vs Cagoco y Ramones
accused was charged in the Court of First Instance of Manila with the crime of
asesinato

W/ON the crime committed by the defendant should be classified

murder when he did not intend to kill the deceased?

Yu Lon and Yu Yee, father and son, stopped to talk on the sidewalk
While they were talking, the man that had been passing back the forth
behind Yu Lon approached him from behind and suddenly and without
warning struck him with his fist on the back part of the head
Yu Lon tottered and fell backwards. His head struck the asphalt
pavement
The wounded man was taken to Hospital, were he died about midnight
the deceased had sustained a lacerated wound and fracture of the skull
in the occipital region, and that he had died from cerebral hemorrhage;
that he had tuberculosis, though not in an advanced stage, and a tumor
in the left kidney.

FACTS

PP vs Bindoy
The crime charged against the accused is homicide

under the circumstances of this case the defendant is liable for the killing of Yu Lon, because his death was
the direct consequence of defendant's felonious act of striking him on the head.

The defendant did commit the crime with treachery, he is guilty of murder, because of the
presence of the qualifying circumstance of treachery.

requisites are present, to wit: (a) That a felony was committed; and (b) that the wrong done to the
aggrieved person be the direct consequence of the crime committed by the offender
nothing to indicate that it was due to some extraneous case. It was clearly the direct consequence
of defendants felonious act, and the fact that the defendant did not intend to cause so great an
injury does not relieve him from the consequence of his unlawful act

ISSUES

RULING