US v. Ah Chong GR No.

L-5272, March 19, 1910

Facts:
The defendant, Ah Chong, was employed as a cook in one of the Officers
quarters at Fort McKinley, Rizal Province. Together living with him in the said quarters was thedeceased,
Pascual Gualberto, who was employed as a houseboy. There had been severalrobberies in Fort
McKinley prior to the incident thus prompting the defendant and his roommateto reinforce the flimsy
hook used to lock the door of their room by placing a chair against it. Thedefendant and the deceased
had an understanding that when either returned at night, he shouldknock on the door and say his
name. On the night of Aug. 14, 1908, Ah Chong, who was alonein his room, was awakened by
someone trying to force open the door of the room. Thedefendant called out twice, asking the identity
of the person but heard no answer. Fearing thatthe intruder was a robber or a thief, the defendant
called out that he would kill the intruder if hetried to enter. At that moment, the door was forced open
and the defendant was struck firstabove the knee by the edge of the chair. Because of the darkness of
the room, the defendantthought he was being hit by the intruder and tried to defend himself by striking
wildly at theintruder using a common kitchen knife which he kept under his pillow. It turned out that the
said
intruder was actually the defendants roommate, Pascual Gualberto. The roommate was
brought to the military hospital where he died from the effects of the wound the following day.
Issue:
WON the defendant was criminally liable for committing a felony.
Held:
Defendant was not criminally liable and exonerated.In order for mistake of fact to be held as a valid
defense, there has to be several requisites.One, that the act done would have been lawful had the facts
been as the accused believedthem to be. Two, that the intention of the accused in performing the act
should be lawful, andlastly, that the mistake must be without fault or carelessness on the part of the
accused.In the case at bar, had the intruder been a robber as the defendant believed him to be, then
AhChong acted in good faith, without malice or criminal intent, and would have been whollyexempt
from criminal liability and that he cannot be said to have been guilty of negligence orrecklessness.
Similar to US v Ah Chong (Digest)

People of the Philippines vs Orlito Villacorta

May 23, 2014
657 SCRA 270 Criminal Law Criminal Liability Proximate Cause Efficient
Intervening Cause
On January 22, 2002, Danilo Cruz went to a sari-sari store to buy bread. Out of nowhere,
Orlito Villacorta appeared and thereafter stabbed the left part of the body of Cruz with a
sharpened bamboo stick. After that, Villacorta fled.
Cruz was helped by bystanders and he was brought to a nearby hospital where he was
treated as out-patient. He was discharged on the same day but on February 14, 2002, or
21 days after the stabbing incident, he returned to the same hospital where he was
treated for severe tetanus. The next day on February 15, 2002, Cruz died. The medical
report states that Cruz died of tetanus infection secondary to stab wound.
The trial court as well as the Court of Appeals convicted Villacorta for murder.
ISSUE: Whether or not Villacorta is guilty of murder.
HELD: No. In this case, the proximate cause of the death is not the stabbing done by Villacorta
upon Cruz. There was an efficient intervening cause which appeared between the time of the
stabbing and the time of the death of Cruz.
In explaining this, the Supreme Court took into consideration the fact that severe tetanus (the
kind of tetanus which causes immediate death) has an incubation period of 14 days or less. In
this case, the stabbing made by Vilalcorta could not have caused the tetanus infection as 22
days already lapsed from the time of the stabbing until the date of death of Cruz. Something else
caused the tetanus other than the stabbing in short, Cruz acquired the tetanus 14 days or less
before February 15, 2003 and not on the date of stabbing.
The court explained further:
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. And since we are dealing with a criminal
conviction, the proof that the accused caused the victims death must convince a rational
mind beyond reasonable doubt. The medical findings, however, lead us to a distinct possibility
that the infection of the wound by tetanus was an efficient intervening cause later or between
the time [Cruz] was wounded to the time of his death. The infection was, therefore, distinct and
foreign to the crime.
Villacorta is however guilty of slight physical injuries based on the facts. Neither is he guilty of
attempted nor frustrated murder, his intent to kill was not proven by the prosecution.

PADILLA V DIZON

Facts:

Year 1948, Isabel Padilla Y Angeles purchased a parcel of land in Sampaloc, Manila, said to
contain an area of 233.9 sq. m., covered by Transfer Certificate of Title No. 12243 for P18,000.
That the Parcel of land was resurveyed and was found to only contain 182.9 sq.m.
That the plaintiff after finding the values disparity, asked the vendor to either consider the
sale void, and for the defendant to return the purchased price of 18,000 and get back the land,
or else refund to her about P4,000, the proportionate reduction of the purchase price due to
difference in area.
That after the first judgment where it rendered in favor of the plaintiff and against the
defendant, the defendant filed an appeal and later withdraw the appeal and filed a motion to
comply with the judgment stating that he had chosen the first alternative declaring the deed of
sale rescinded and cancelled, and ordering him to return the purchase price of 18,000. Which
then the trial court by order of June 5, 1951, granted defendants motion.
That after failing to secure a reconsideration of said order, plaintiff filed with the Court of
Appeals a petition for certiorari against the trial Judge to review and set aside the order of June 5,
1951, as well as denying its reconsideration, which on July 21, 1951, the Court of Appeals
dismissed the petition of certiorari. Then plaintiff appealed the resolution of dismissal to the
Supreme Court but by resolution of Tribunal the appeal was dismissed for lack of merit.
That on September 6, 1951, plaintiff filed a manifestation of waiver of her rights in the
decision rendered in her favor by the trial court, on the basis of Article 4, paragraph 2 of the old
Civil Code. Which states:
Rights granted by law may be waived, provided such waiver be not contrary to public
interest or public order, or prejudicial to a third person.

Issue:

Whether or not the plaintiff has the right to waive her rights on the decision
rendered in her favor by the trial court.
Held:
The orders appealed from particularly that of June 5, 1951, are hereby affirmed, with costs.
On the stand that:
The very law she invokes provides that rights may be waived unless such waiver is
contrary to law, public order, public policy, morals or good customs, or prejudicial to a third
person with a right recognized by law. When, acting upon her complaint which was asked
for two alternative remedies in which he(defendant) chose one to comply, upon the action he
acquired a right recognized by law, and he would be prejudiced by a subsequent waiver on the
part of the plaintiff of her right acquired under the decision.
From another point of view, the complaint filed by the plaintiff may be regarded as an
offer by her thru the court, when the defendant expressed to the court his willingness, readiness
and ability to comply with the said decision, particularly the part or alternative ordered in it, that
may be considered as a formal acceptance of the offer made by the plaintiff; and thereafter the
plaintiff cannot back out, and withdrew her offer. Acceptance of an offer gives the offeree a right
to compel the offeror to comply with the offer.
When after hearing, the trial court by its decision granted that part of the prayer contained in the
complaint to have the deed of sale declared null or rescinded on the ground of fraud and
misrepresentation as to the area of the land, and when that decision became final, the deed of
sale was for all legal purposes declared rescinded and there was nothing that the plaintiff could

do about it, especially after the defendant had accepted that judicial declaration of rescission
and had offered to comply with his obligation to return the purchase price

PEOPLE V BUAN

FACTS: On July 23, 1962, the accused, Mr. Jose Buan, was driving a passenger bus of La
Mallorca Company along the McArthur Highway in the municipality of Guiguinto Bulacan.
His vehicle driven suddenly struck and collided with the passenger jeep of Sergio
Lumidao, damaging and causing the jeep to turn turtle, and injuring the passengers. Six
of the jeepney passenger suffered slight physical injuries requiring medical attendance
for 5 to 9 days; 3 others with serious bodily injuries that needed medical attention for 30
to 45 days, while the jeep was damaged to the extent of Php 1,395.00.

ISSUE: Whether or not the appellant will be charged of double jeopardy for the same
offense and is barred by the previous acquittal.

HELD:

In view of the foregoing, we must perforce rule that the exoneration of this appellant,
Jose Buan, by the Justice of the Peace (now Municipal) Court of Guiguinto, Bulacan, of the charge
of slight physical injuries through reckless imprudence, prevents his being prosecuted for serious
physical injuries through reckless imprudence in the Court of First Instance of the province,
where both charges are derived from the consequences of one and the same vehicular accident,
because the second accusation places the appellant in second jeopardy for the same offense.
WHEREFORE, the order appealed from is reversed, and the Court of First Instance of Bulacan is
directed to quash and dismiss the charge in its Criminal Case No. 5243. No costs. So ordered.

(CRIMINAL LAW AND PROCEDURE; DOUBLE JEOPARDY; QUASI OFFENSE OF CRIMINAL

NEGLIGENCE; SUBSEQUENT PROSECUTION FOR THE SAME ACT. Once convicted or acquitted of
a specific act of reckless imprudence, the accused may not be prosecuted again for that same
act. The essence of the quasi offense of criminal negligence under article 365 of the Revised
Penal Code lies in the execution of an imprudent or negligent act that, if intentionally done,
would be punishable as a felony. The law penalizes the negligent or careless act, not the result
thereof. The gravity of the consequence is only taken into account to determine the penalty; it
does not qualify the substance of the offense. As the careless act is single, whether the injurious
result should affect one person or several persons, the offense remains one and the same. It
cannot be split into different crimes and prosecutions.)