Ramirez vs. CA G.R. No.

93833 September 28, 1995

Facts:

Petitioner Socorro D. Ramirez filed a civil case in the Regional Trial Court of Quezon City alleging that the
private respondent, Ester S. Garcia, in a confrontation in the latter's office, allegedly vexed, insulted and
humiliated her in a "hostile and furious mood" and in a manner offensive to his dignity and personality,
contrary to morals, good customs and public policy.

In support of her claim, petitioner produced a verbatim transcript of the event and sought moral
damages, attorney's fees and other expenses of litigation in the amount of P610,000.00, in addition to
costs, interests and other reliefs awardable at the trial court's discretion. The transcript on which the
civil case was based was culled from a tape recording of the confrontation made by petitioner.

As a result of petitioner's recording of the event and alleging that the said act of secretly taping the
confrontation was illegal, private respondent filed a criminal case before the Regional Trial Court of
Pasay City for violation of Republic Act 4200, entitled "An Act to prohibit and penalize wire tapping and
other related violations of private communication, and other purposes.

Issue:

Whether or not the applicable provision of Republic Act 4200 does not apply to the taping of a private
conversation by one of the parties to the conversation.

Ruling:

No. Section 1 of the Republic Act 4200 states that it shall be unlawful for any person, not being
authorized by all the parties to any private communication or spoken word, to tap any wire or cable, or
by using any other device or arrangement, to secretly overhear, intercept, or record such
communication or spoken word by using a device commonly known as a dictaphone or dictagraph or
detectaphone or walkie-talkie or tape recorder, or however otherwise described.

The law is clear and unambiguous. Where the law makes no distinctions, one does not distinguish. The
Supreme Court affirmed the appealed decision. The instant petition is hereby DENIED. Cost against
petitioner.
People vs. Jabinal GR No. L-30061 (February 27, 1974)

Facts:

Jabinal was found guilty of the crime of Illegal Possession of Firearm and Ammunition.

The accused admitted that he was in possession of the revolver and the ammunition described in the
complaint, without the requisite license or permit. He, however, claimed to be entitled to exoneration
because, although he had no license or permit, he had an appointment as Secret Agent from the
Provincial Governor of Batangas and an appointment as Confidential Agent from the PC Provincial
Commander, and the said appointments expressly carried with them the authority to possess and carry
the firearm in question.

The accused contended before the court that he was entitled to acquittal on the basis of the Supreme
Courts decision in People vs. Macarandang(1959) and People vs. Lucero(1958) and not on the basis of
the latest reversal and abandonment in People vs. Mapa (1967).

Issue:

Whether or not appellant should be acquitted on the basis of the courts rulings in Macarandang and
Lucero, or should his conviction stand in view of the complete reversal of the MAcarandang and Lucero
doctrine in Mapa.

Ruling:

Decisions of this Court, under Article 8 of the New Civil Code states that Judicial decisions applying or
interpreting the laws or the Constitution shall form a part of the legal system . The settled rule
supported by numerous authorities is a restatement of legal maxim legis interpretatio legis vim
obtinet the interpretation placed upon the written law by a competent court has the force of law.

Appellant was appointed as Secret Agent and Confidential Agent and authorized to possess a firearm
pursuant to the prevailing doctrine enunciated in Macarandang and Lucero under which no criminal
liability would attach to his possession of said firearm in spite of the absence of a license and permit
therefore, appellant must be absolved. Certainly, appellant may not be punished for an act which at the
time it was done was held not to be punishable.

The appellant was acquitted.

Ruffy vs. Chief of Staff G.R. No. L-53375 Phil 875 August 20, 1956

Facts:

During the Japanese insurrection in the Philippines, military men were assigned at designated camps or
military bases all over the country. Japanese forces went to Mindoro thus forcing petitioner and his
band move up the mountains and organize a guerilla outfit and call it the "Bolo area". A certain Capt.
Beloncio relieved Ruffy and fellow petitioners of their position and duties in the "Bolo area" by the new
authority vested upon him because of the recent change of command. Capt. Beloncio was thus allegedly
slain by Ruffy and his fellow petitioners.

Issue: Whether or not the petitioners were subject to military law at the time the offense was
committed, which was at the time of war and the Japanese occupancy.

Ruling:

The Court held that the petitioners were still subject to military law since members of the Armed Forces
were still covered by the National Defense Act, Articles of War and other laws even during an
occupation. The act of unbecoming of an officer and a gentleman is considered as a defiance of 95th
Article of War held petitioners liable to military jurisdiction and trial. Moreover, they were operating
officers, which makes them even more eligible for the military court's jurisdiction.

In consideration of the foregoing, the petition has no merit and should be dismissed. Thus, the petition
is hereby DENIED.
U.S. v. Sweet, 1 Phil. 18 (1901)

Facts:

Sweet was employed by the United States military who committed an offense against a POW. His case
is filed with the CFI, who is given original jurisdiction in all criminal cases for which a penalty of more
than 6 months is imposed. He is now contending that the courts are without jurisdiction because he was
acting in the line of duty.

Issue:

Whether or not this case is within the jurisdiction of the CFI

Ruling:

Yes. By Act No. 136 of the US-Phil Commission, the CFIs are given original jurisdiction in all criminal cases
in which a penalty more than 6 months imprisonment or a fine greater than $100 may be imposed.
Furthermore, CFIs have jurisdiction to try offenders charged with violation of the Penal Code within their
territorial limits. The application of the general principle that the jurisdiction of the civil tribunals is
unaffected by the military or other special character brought before them for trial regardless of the
military character of the accused. The defendant and his acts are within the jurisdiction of the CFI
because he failed to prove that he was indeed acting in the line of duty.
Kuroda v. Jalandoni, G.R. No. L-2662, March 26, 1949

Facts:

Petitioner Shigenori Kuroda, the Commanding General of the Japanese Imperial Forces in the Philippines
during the Japanese occupation, was charged before the Philippine Military Commission of war crimes.
He questioned the constitutionality of E.O. No. 68 that created the National War Crimes Office and
prescribed rules on the trial of accused war criminals. He contended the Philippines is not a signatory to
the Hague Convention on Rules and Regulations covering Land Warfare and therefore he is charged of
crimes not based on law, national and international.

Issue:

Whether or not E.O. No. 68 valid and constitutional?

Ruling:

YES, E.O. No. 68 valid and constitutional.

Article 2 of our Constitution provides in its section 3, that

The Philippines renounces war as an instrument of national policy and adopts the generally accepted
principles of international law as part of the law of the nation.

It cannot be denied that the rules and regulation of the Hague and Geneva conventions form, part of
and are wholly based on the generally accepted principals of international law. Such rule and principles
therefore form part of the law of our nation even if the Philippines was not a signatory to the
conventions embodying them for our Constitution has been deliberately general and extensive in its
scope and is not confined to the recognition of rule and principle of international law as contained in
treaties to which our government may have been or shall be a signatory.
People V. Wong Cheng (1922)

Facts:

Appellant is accused of having 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. The Lower court dismissed the case.

Issue:

Whether or not the courts of the Philippines have jurisdiction over crime committed aboard merchant
vessels anchored in our jurisdiction waters

Ruling: The order appealed from is revoked and the cause ordered remanded to the court of origin for
further proceedings in accordance with law, without special findings as to costs.

French rule-according to which crimes committed aboard a foreign merchant vessel should not be
prosecuted in the courts of the country within whose territorial jurisdiction they were committed unless
their commission affects the peace and security of the territory.

Mere possession of opium aboard a foreign vessel in transit was held by this court not triable by or
courts, because it being the primary object of our Opium Law to protect the inhabitants of the
Philippines against the disastrous effects entailed by the use of this drug, its mere possession in such a
ship, without being used in our territory, does not being about in the said territory those effects that our
statute contemplates avoiding. Hence such a mere possession is not considered a disturbance of the
public order.

To smoke opium within our territorial limits, even though aboard a foreign merchant ship, is certainly a
breach of the public order here established, because it causes such drug to produce its pernicious
effects within our territory.
US. V. Ah- Sing, 36 Phil. 987

G.R. No. L-13005. October 10, 1917.

Facts:

Ah Sing is a chinaman at the steamship Shun Chang, a foreign vessel which arrived in the port of Cebu
from Saigon.

He bought 8 cans of opium in Saigon, brought them on board and had them in his possession during the
trip. The 8 cans of opium were found in the ashes below the boiler of the steamer's engine by
authorities who made a search upon anchoring on the Cebu port.

Ah Sing confessed that it was his and that it was bought in Saigon without stating his intention.

CFI of Cebu held that Ah Sing is guilty in violation of the Opium Law

Issue: Whether or not the crime of illegal importation of opium into the Philippine Islands is criminally
liable in the Philippines

Ruling:

Yes. Ah Sing having been proved guilty beyond a reasonable doubt

As applied to the Opium Law, we expressly hold that any person unlawfully imports or brings any
prohibited drug into the Philippine Islands, when the prohibited drug is found under this person's
control on a vessel which has come direct from a foreign country and is within the jurisdictional limits of
the Philippine Islands.

In such case, a person is guilty of illegal importation of the drug unless contrary circumstances exist or
the defense proves otherwise.

Applied to the facts herein, it would be absurd to think that the accused was merely carrying opium back
and forth between Saigon and Cebu for the mere pleasure of so doing. It would likewise be impossible
to conceive that the accused needed so large an amount of opium for his personal use. No better
explanation being possible, the logical deduction is that the defendant intended this opium to be
brought into the Philippine Islands.
US vs. Look Chaw, December 16, 1911

Facts:

Several persons went aboard the steamship Erroll to inspect and search its cargo. Note that steamship
Erroll is of English nationality and it came from HongKong bound for Mexico via the call ports of Manila
and Cebu. These persons found sacks of opium.

The complaint filed against defendant stated that defendant carried, kept, possessed, and had in his
possession and control 96 kg of opium and that he he had been surprised in the act of selling P1,000
worth prepared opium. However, since there was more than 1 crime charged, the fiscal just filed for
unlawful possession of opium

According to the testimony of the internal-revenue, the opium seized in the vessel had been bought by
the defendant in HongKong, at P3.00 for each round can and P5.00 for each of the others, for the
purpose of selling it, as contraband, in Mexico and Puerto de Vera Cruz; that the vessel arrived at Cebu
and on the same day he sold opium.

Issue: Whether or not the Philippine courts have jurisdiction

Held: Yes, the Philippine courts have jurisdiction.

Mere possession of a thing of prohibited use in the Philippine Islands, aboard a foreign vessel in transit,
in any of their ports, does not, as a general rule, constitute a crime triable by the courts of the
Philippines. However, in the case at bar, a can of opium is landed from the vessel upon Philippine soil,
thus committing an open violation of the Philippine laws.
United States vs. Fowler December 31, 1902 (1 Phil 614)

Facts:

August 12, 1901, the defendants were accused of the theft of 16 champagne bottles worth 20 dollars
while on board the vessel Lawton. The counsel for defendants alleged to the Court of First Instance
that they were without jurisdiction over the crime charged . Since it happened in the high seas and not
in the city of Manila or in the territory in which the jurisdiction of the court extends, they asked that the
case be dismissed.

Issue:

Whether or not the Court of First Instance has jurisdiction over crimes committed on the high seas on
board of transport not registered in the Philippines.

Held:

No. The Philippine court has no jurisdiction over the crime of theft committed on high seas on board a
vessel not registered or licensed in the Philippines. The transport Lawton not being a vessel of this
class, our courts are without jurisdiction to take a cognizance of a crime committed on board the same.
US vs Bull, 15 Phil 7

Facts:

On December 2, 1908, a steamship vessel engaged in the transport of animals named Stanford
commanded by H.N. Bull docked in the port of Manila, Philippines. It was found that said vessel from
Ampieng, Formosa carried 674 heads of cattle without providing appropriate shelter and proper suitable
means for securing the animals which resulted for most of the animals to get hurt and others to have
died while in transit.

This cruelty to animals is said to be contrary to Acts No. 55 and No. 275 of the Philippine Constitution. It
is however contended that cases cannot be filed because neither was it said that the court sitting where
the animals were disembarked would take jurisdiction, nor did it say about ships not licensed under
Philippine laws, like the ships involved.

Issue:

Whether or not the court had jurisdiction over an offense committed on board a foreign ship while
inside the territorial waters of the Philippines.

Held:

Yes. When the vessel comes within 3 miles from the headlines which embrace the entrance of Manila
Bay, the vessel is within territorial waters and thus, the laws of the Philippines shall apply. A crime
committed on board a Norwegian merchant vessel sailing to the Philippines is within the jurisdiction of
the courts of the Philippines if the illegal conditions existed during the time the ship was within the
territorial waters - regardless of the fact that the same conditions existed when the ship settled from the
foreign port and while it was on the high seas.

In light of the above restriction, the defendant was found guilty and sentenced to pay a fine of two
hundred and fifty pesos with subsidiary imprisonment in case of insolvency, and to pay the costs.
Us vs. Cuna 12 phil rep. 241 Dec. 15, 1908

Facts:

The provincial fiscal of the province of Isabela filed an information charging the defendant Chinaman
Cuna for violation of an opium law for selling a small quantity of opium to a Filipino woman, who was
neither a doctor, pharmacist, or vendor of opium with license, all contrary to law.

Defendant claims, relying on American and English common law, where the repeal of a penal statute
operates as a remission of penalties for violations of it committed, and for its release from prosecution.
That since the provision of the law that was violated was repealed and there was no law in force which
penalizes the alleged offense, therefore the court has no jurisdiction over the case.

Issue:

Whether or not the defendant is still criminally liable because of the repeal.

Ruling:

Yes. The Court ruled that the reliance of the defendant of the American and English common law is not
and has not been the accepted doctrine, the courts in the Phil. Islands are not deprived of jurisdiction to
try the accused. That laws shall have no retroactive effect unless favorable to the offender, is not
applicable to acts of the Phil. Commission or the Phil. Legislature.
US. Vs. Abad Santos 36 Phil. Rep 243 Feb. 10, 1917

Facts:

The appellant is the owner of a printing establishment and was required by law to keep a book where he
make the entries required. Appellant was charged in an information that he violated the provisions of
said regulation, when one day he failed to make an entry, indicating whether any business was done in
that day or not. Such omission was done by appellants bookkeeper.

Issue:

Whether or not the accused is liable for the acts of another.

Ruling:

No. The court is upon opinion that he must be acquitted.

It was undisputed that he regularly employed a bookkeeper who was in complete charge of the book
where entries should have been made, where the failure to make an entry was due to the bookkeeper
of which appellant knew nothing. A person is not criminally liable for the acts of another without his
knowledge or consent, unless the law clearly so provides.
People vs. Sara 55 Phil. Rep. 939 Aug. 15 1931

Facts:

Francisco Sara, armed with a shotgun, was out in a barrio with the design of shooting birds. At the same
time a couple was out collecting bananas. A witness saw the incident where the discharge of a gun was
heard, and the saw the wifes husband stretched on the ground as he was hit in the abdomen. They saw
the accused running away carrying a gun.

Issue:

Whether or not there was deliberate intent to kill by the accused.

Ruling:

No, there was no intent although the accused was responsible for homicide.

Homicide resulted from the discharge of the gun in the hands of the accused but the relations between
them were such as to negate any direct intention on his part to do bodily harm.
People vs. Silvestre and Atienza 56 Phil Rep. 353 Dec. 14 1931

Facts:

The accused Atienza cohabited with co- accused Silvestre at the home of co-accuseds son by her former
marriage. While they are gathered together after eating supper, accused Atienza ordered the co-
accuseds son and his wife to take out the furniture because he was going to set fire on it, because he
wanted to get revenged upon the people who instigated the charge of adultery against him and his co-
accused. Accused Silvestre did not raise protest and did not give alarm when the latter set fire to the
house. The lower court found her guilty of arson as an accomplice.

Issue:

Whether or not Accused Silvestre is guilty as an accomplice for not giving alarm of the incident.

Ruling:

The Court ruled that mere passive presence at the scene of anothers crime or mere silence and failure
to give the alarm without evidence of agreement or conspiracy does not constitute cooperation for
commission of the crime. Accused Silvestre was acquitted.
People vs. Gonzales 183 SCRA 309 March 19 1990

Facts:

Spouses Augusto and Fausta Gonzales surrendered to the authorities when, Augustos wife killed their
landlord. Jose Huntoria a witness claimed to have witnessed the killing, and mentioned additional
accused. When was passing at the vicinity of the spouses house he heard cries for help. He hid himself
behind the clump of banana trees, and allegedly saw all the accused ganging up on the deceased, taking
turns in stabbing and hacking him.

Issue:

Whether or not all the accused mentioned by the witness had a direct participation in killing the victim.

Ruling:

No. The court dismissed the witness testimony because the prosecution cannot prove direct
participation on all the accused, when he admitted that he could not determine who among the six
accused did the stabbing or hacking of the victim. Appellant was acquitted.
US vs. Penalosa 1 Phil Rep. 109 Jan 27 1902

Facts:

Accused was convicted by the lower court for having contracted an illegal marriage without consent of
her parents, as she was not 21 years of age at the time when she married. She contends that she was of
age

Issue:

Whether or not she is liable for illegal marriage

Ruling:

No. The court held that the defendant stated that she believed that she was born in 1879 that her
parents had given her to understand since at her childhood. Being true, they disclose that she acted
under a mistake of fact. The court acquitted the accused.
People vs. Ramirez 48 Phil. Rep 204 Nov .3 ,1925

Facts:

The accused together with his companions and deceased went out to the woods to hunt. Upon arriving
at the place, accused carrying a shotgun while holding a lantern, happened to spot a deer. He told his
companions to stay and watch over the prey while he entered the forest to get it. While waiting, they
suddenly heard the discharge of the shotgun and hit the deceased in the eye and the right temple.

Issue:

Whether or not the accused is liable for homicide

Ruling:

Yes. Where it appears that the accused killed the deceased while hunting at night by shooting him in
the belief that he was a deer the court held that he is liable of homicide through reckless imprudence
since he has not exercised due diligence to avoid the accident.
People vs. Bayona 61 Phil 181 Feb. 16 1935

Facts:

The CFI found the defendant guilty of violation of a provision of the Election Law for carrying a firearm in
an election polling place. The defendant contends that he was not guilty, because he was called by a
friend and approached him and that he had no interest in the election. That because there were so
many people, the defendant could not risk losing his revolver in his automobile, in which he decided to
carry it with him.

Issue:

Whether or not defendant is guilty of violating the said law.

Ruling:

Yes. The court ruled that the law which the defendant violated is a statutory provision, and the intent
with which he violated is immaterial. The court distinguished acts that are mala in se requires criminal
intent, and acts mala prohibita, it is sufficient that the prohibited act was done. The law in question is
under acts mala prohibita, therefore intent is not required to commit the violation.
US. Vs. Catangay 28 Phil 490 Nov.25, 1914

Facts:

Three men were hunting deer at night. One of them carried a lantern fastened to his forehead. His other
companions followed him. Then they saw a deer. The accused, whose gun was already cocked aimed at
the deer but he stumbled against an embankment which lay between him and the deceased. His gun
was accidentally discharged, hitting and killing the deceased. The RTC ruled convicting the accused with
homicide through reckless negligence, because he did not take necessary precaution.

Issue:

Whether or not there was negligence resulting with homicide.

Ruling:

No. The Court held that Catangay was not criminally liable because he had no criminal intent and was
not negligent. He was going for along with his eyes fixed on the deer, the embankment attributed to
what was an unforeseen and unfortunate accident for which defendant cannot be held liable. Accused
was acquitted.
US vs. Siy Cong Bieng 30 Phil 577

Facts:

Co Kong, was in charge of appellants store, acting as his agent and employee, sold in the ordinary
course of business, coffee which had been adulterated by the admixture of peanuts and other
extraneous substances. He was convicted by the lower court of violation of a provision of the Food and
Drugs Act.

Issue:

Whether or not criminal intent or guilty knowledge is required to sustain conviction of a violation of a
statute.

Ruling:

No. The court held in the case at bar that the principal may be held criminally liable for the act, omission
or failure of his employee for the prohibited sale of adulterated coffee, although it appeared that the
principal had no guilty knowledge of the fact that the coffee is adulterated or that such had been sold by
his agent.
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 Officersquarters at Fort McKinley, Rizal
Province. Together living with him in the said quarters was the deceased, 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 lock of 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. Onenight,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 saidintruder was actually the defendants roommate, PascualGualberto who 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.
People vs. Sia Teb Ban G.R. No. L-31695 November 26, 1929

Facts:

Found guilty of qualified theft and habitual delinquency, the defendant was sentenced by the municipal
court of Manila and on appeal, by the Court of First Instance of this City, to two years, four months, and
one day presidio correccional, with costs, and to the additional penalty of twenty-one years'
imprisonment.

He now contends that he is not guilty of the crime with which he is charged.

Issue: Whether or not the accused is liable for his acts.

Held:

It has been proved that he took the watch described in the information without the owner's consent,
having been overtaken a few moments later by a friend of the offended party, who found the stolen
watch on the appellant. It is alleged that animus lucrandi has not been proved. We find it sufficiently
established, as the acts of the accused shows his intention.

It is a fundamental doctrine of law that the act penalized by the law is presumed to be voluntary unless
contrary is shown. And from the appellant's felonious acts, freely and deliberately executed, the moral
and legal presumption of a criminal and injurious intent arises conclusively and indisputably, in the
absence of evidence to the contrary the appealed judgment is modified, the appellant being sentenced
to the accessory penalties provided in article 58 of the Penal Code.
US vs. Catolico GR No 6486 18 Phil 504 02 March 1911

Facts: The justice of peace of Cagayan had before him 16 separate civil cases initiated by Juan Canillas
for damages resulting from breach of contract. All cases were decided in favor of Canillas and all
defendants appealed the decision and deposited Php 16 and a bond of Php 50 as required by law. It
appears that the sureties of the bond were insolvent and new bonds were not presented on the
extension given. Canillas appealed. The justice of peace dismissed the appeals and ordered the sm of
money attached and delivered to Canillas in satisfaction of the judgment. The judge was prosecuted for
malversation of funds.

Issue: Whether or not the defendant is guilty of felony.

Ruling:

Judgment of conviction is reversed and defendant ordered to be discharged from custody.The judge
decided in good faith under the belief that he was acting judiciously and correctly. It was a result of
erroneous exercise of judicial function and not an intention to deprive any person of his property
feloniously. He acted that debts might be paid to those who they are legally and justly due and not to
enrich himself or another by criminal misappropriation. It was a mistake not a crime.
People vs. Taneo March 31, 1933 (58 Phil 255)

Facts:

On January 16, 1932, in the house of PotencianoTaneos parents in Dolores, Ormoc, Leyte, because of
severe stomachache, Potenciano slept early. While sleeping, he suddenly got up, left the room with a
bolo in hand and upon meeting his wife who tried stop him, he wounded her int eh abdomen. Several
others were also attacked, this includes his father, and his guests, Fred Tanner and Luis Malinao. It was
claimed that he was dreaming when the crime happened. The trial court found Potenciano guilty of
parricide and was sentenced to reclusion perpetua.

Issue:

WON the defendant is criminally liable.

Ruling:

No. The defendant acted while in a dream and his acts with which he was charged were not voluntary in
the sense of entailing criminal liability. The expert witness claimed that the defendant was under the
influence of hallucination and not in his right mind. The defendant is not criminally liable however, he
was ordered to be confined in an insane asylum.
People vs. Beronilla 96 Phil. 566 (1955)

Facts:

Arsenio Borjal was mayor of La Paz Abra at the outbreak of war and continued to serve as mayor during
the Japanese occupation. Dec 19, 1944 accused-appellant Manuel Beronilla was appointed Military
Mayor of La Paz by LT. Col Arnold. Simultaneously, he received a memorandum issued by Arnold
authorizing them to appoint a jury of 12 bolomen to try persons accused of treason, espionage or aiding
the enemy. Beronilla, pursuant to his instructions placed Borjal under custody and asked residents of La
Paz to file case against him. The jury found Borjal guilty on all counts and imposed death penalty. Mayor
Beronilla forwarded the records of the case to Headquarters of Infantry for review. Records were
returned on April 18,1945 with approval of Arnold. On the same day, Beronilla ordered the execution of
Borjal. Immediately after the execution, Beronilla reported the execution to Arnold, the latter
complementing Beronilla.

Two years later, Mayor Beronillo and others involved in the Borjal case were indicted by CFI of Abra for
murder, for allegedly conspiring and confederating in the execution of Borjal. Hence they appealed to
the court.

Issue:

Whether or not accused appellants are guilty of murder;

Held: The records are ample to show that Beronilla acted pursuant to the orders of the Infantry
Headquarters. Although it was alleged by the state that there was a radiogram from certain Col.
Volkmann to Lt. Col. Arnold, on the illegality of Borjal's execution, there are no sufficient evidence to
show that it was known to Beronilla. Furthermore, the messages of Col. Arnold approving the decisions
of Beronilla prove otherwise. The court said that the conduct of the appellants does not dispose that
they were impelled by malice. The court held that the accused-appellants just acted upon the orders of
superiors and criminal intent was not established.
People vs. Oanis, 74 Phil. 257

Facts:

Chief of Police Oanis received a telegram of the following tenor: "Information received escaped convict
AnselmoBalagtas with bailarina and Irene in Cabanatuan get him dead or alive." Defendants Oanis and
Galanta were one of the people tasked to apprehend the convict.

Defendants went to the room of Irene, and upon 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
however it turned out later that the person shot and killed was not the notorious criminal Anselmo
Balagtas but a peaceful and innocent citizen named SerapioTecson, Irene's paramour.

According to Appellant Galanta, when he and chief of police Oanis arrived at the house, the latter asked
Brigida where Irene's room was. Brigida indicated the place, and upon further inquiry as to the
whereabouts of Anselmo Balagtas, she said that he too was sleeping in the same room.

Issue: Whether or not defendants are responsible for the death thus caused to Tecson.

Ruling: Yes. Appellants were declared guilty of murder.

Mistake of fact may relieve one from criminal liability, but this applies only when the mistake is
committed without fault or carelessness. Appellants 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, as the victim was unarmed.

The crime committed by appellants is not merely criminal negligence, the killing being intentional and
not accidental. In criminal negligence, the injury caused to another should be unintentional, it being
simply the incident of another act performed without malice.
People vs. De Fernando 49 Phil. 75

Facts:

The accused, a policeman, was informed that three convicts had escaped.In the dark, he saw a person
going up the stairs of a house, carrying a bolo andcalling for someone inside. The daughter of the owner
of the house was at that time with the accused whofired a shot in the air. As the unknown
personcontinued to ascend the stairs and believing that he was one of the escapedconvicts, the accused
fired directly at the man who turned out to be the nephewof the owner of the house

Issue: Whether or not the appellant is exempt from criminal liability due tomistake of fact.

Ruling: An agent of the law, to whom notice had been given of the presence of suspicious looking
persons, who might be escaped prisoners prowling around the vicinity, and who enters a house to
keepwatch, and later in the evening sees a person with a bolo in hand, approachingthe house in the
attitude of going up the stairs, who does not answer thechallenge of the officer of the law, even when
the latter had fired a shot into the air, thinking him to be an evil-doer, shoots and kills him, is not
guiltyof murder or homicide.Taking into consideration the state of the mind of the accused at the time,
in shooting thelatter, he felt that he was performing his duty by defending the owners of thehouse
against an unexpected attack, and such act cannot constitute the crime of murder, but only that of a
simple homicide.
People v. Guillen GR No. L-1477, January 18, 1950

Facts:

The accused Julio Guillen, was found guilty of thecrime of murder and multiple frustrated murder after
his attempt to assassinate the President of the Philippines, Manuel Roxas. During the 1946 Presidential
Elections, Guillen voted for the opposing candidate of Manuel Roxas because he was disappointed with
him for failing to fulfill his promises made during the elections. The accused determined to assassinate
the President and found the oppoturnity when the President attended a popular meeting at Plaza de
Miranda, Quiapo, Manila. He thought of using two hand grenades which were given to him by an
American soldier for two bottles of whisky. The accused stood on a chair and hurled the grenade at the
President when he had just closed his speech. A general who was on the platform saw the smoking
grenade and kicked it away from the platform towards an open space where he thought the grenade
would do the least harm. The grenade exploded in the middle of a group of persons and killed one
person, and injured several other persons. Guillen was arrested and he readily admitted his
responsibility.

Issue:

Whether or not the accused was guilty only of homicide through reckless imprudence in regard to
thedeath of Simeon Varela and of less serious physical injuries in regard to the other injuredpersons.

Ruling :

The facts do not support the contention of the counsel for the appellant. In throwing the handgrenade
at the President with the intention of killing him, the appellant acted with malice and is therefore liable
for all the consequences of his wrongful act. Art. 4 of the Revised Penal Code, states that criminal
liability is incurred by any person committing a felony althoughthe wrongful act done be different from
that which he intended. Where such unlawful act is wilfully done, a mistake in the identity of the
intended victim cannot be considered reckless imprudence.
US vs. Go Chico (14 Phil 133)

Facts: appellant Go Chico displayed in one of the windows and one of the show cases of his store a the
flag or banner or device used during the late insurrection in the Phil. Islands to designate and identify
those in armed insurrection against the United States. He was arranging his stock of goods for the
purpose of displaying them to the public, and in doing so, he placed it in his showcase and on one of the
windows of his store. The appellant was ignorant of a law against the display of such and had
consequently no corrupt intention. The facts stated above are admitted. The appellant has two
propositions for his acquittal: first is that before a conviction can be had, a criminal intent upon the part
of the accused must be proved beyond a reasonable doubt. Second is that the prohibition of law is
directed against the use of identical banners, devices or emblems actually used during the Philippine
insurrection by those in armed rebellion against the United States.

Issue: Whether or not criminal intent is necessary in crimes punishable by special laws.

Held: The court ruled that the act alone, irrespective of its motive, constitutes the crime. The words
used during the late insurrection in the Philippine Islands to designate or identify those in armed
rebellion against the United States mean not only the identical flags actually used in the insurrection,
but any flag which is of that type. The description refers not to a particular flag, but to a type of flag. The
literal interpretation of a statute may lead to an absurdity, or evidently fail to give the real intent of the
legislature.
People v. Ural [56 SCRA 138 (1974)]

Facts: Ural, a policeman, boxed the deceased, Felix Napola, a detention prisoner, inside the jail. As a
consequence, the deceased collapsed on the floor and the accused stepped on the prostate body and
left. After a while he returned with a bottle poured its contents on the recumbent body of the deceased,
ignited it with a match and left the cell again. As a consequence, the victim later on died of the burns.
The crime committed by appellant Ural was murder by means of fire.

Issue: Whether or not the accuseds contention of lack of intention to commit so grave a wrong is valid.

Held: The trial court correctly held that the accused took advantage of his public position but it failed to
appreciate the mitigating circumstance of no intention to commit so grave a wrong as that committed.
The intention, as an internal act, is judged not only by the pro-portion of the means employed by him to
the evil produced by his act, but also by the fact that the blow was or was not aimed at a vital part of the
body. Thus, it may be deduced from the proven facts that the accused had no intent to kill the victim, his
design being only to maltreat him, such that when he realized the fearful consequences of his felonious
act, he allowed the victim to secure medical treatment at the municipal dispensary.

Lack of intent to commit so grave a wrong offsets the generic aggravating, circumstance of abuse of his
official position. The trial court properly imposed the penalty of reclusion perpetua which is the medium
period of the penalty for murder.
US vs. Divino, 12 Phil 175

Facts: A girl named Alfonsa, about 13 years of age when the incident happened, was a servant for
Feliciano Divino and his family. Her feet were the focus in this case because it is said that Feliciano
Divino burned her feet, in a very unorthodox and harmful way in a sense, by setting her feet on fire after
applying petroleum to it and tying her down to the floor. He argued in the court that when Alfonsa came
to their home, her body was full of scars and ulcers, and that the ulcer in her body was cured, through
his efforts.

Issue: Whether Feliciano Divino can be acquitted because he argued that he acted in good faith and did
not mean any harm to the girl, except to help her get cured.

Held: Medical arguments were brought in the light of the decision and that a doctor clearly identified
that the scars on Alfonsas feet were indeed because of burns and that the wounds became worse on
account of Felicianos efforts to cure them. Certainly it was found certain that the acts of the guilty
person do not seem to have been intended to cause an evil, but rather as a remedy. However, article
568 or the Penal Code clearly states that a person that undertakes medical assistance to another person
is liable for any injuries resulting from such treatment, and the fact that he acted in good faith and
according to the best of his ability does not relieve him from responsibility, although his ignorance may
be considered as a mitigating circumstance.
People vs. Bindoy G.R. NO. L-34665 August 28, 1931

Facts:

In the afternoon of May 6, 1930, a disturbance arose in a tuba wineshop. Donato Bindoy offered some
tuba to Faustino Paca's wife Tibay. She refused because she already have one, but Bindoy threatened to
injure her if she did not accept. Pacas stepped in to defend his wife, attempting to take away from
Bindoy the bolo he carried. Emigdio Omamdam who came to the wine shop to see whats happening,
instead got stabbed in the chest by Bindoy. This happened when Bindoy succeeded in disengaging
himself from Pacas, wrenching the bolo from the latter's hand towards the left behind the accused and
with such violence that the point of the bolo reached Omamdam's chest who was then behind Bindoy.

Issue: Whether or not Bindoy is criminally liable?

Ruling: Corroborated by a witness of the testimony of the accused, Pacas and Bindoy were actually for
the possession of the bolo. When Pacas let go of the bolo, Bindoy had pulled so violently that it flew
towards his left side, at the very moment when Emigdio Omamdam came up and who was therefore hit
in the chest without Bindoy seeing him. Bindoy alleges that it was caused accidentally and without
malicious intent because he was only defending his possession of the bolo which Pacas was trying to
wrench away from him and his conduct was perfectly lawful. The Court therefore acquitted Bindoy
based on the facts stated.
People vs. Cagoco GR No. L-38511October 6, 1933

Facts:

The accused willfully, unlawfully, feloniously, without any just cause therefor and with intent to kill and
treachery, assaulted and attacked Yu Lon by suddenly giving hima fist blow on the back part of the head,
treacherously under conditions which intended directly and especially to insure, the accomplishment of
his purpose without risk to himself arising from any defense the victim Yu Lon might make, thus causing
him to fall on the ground as aconsequence of which he suffered a lacerated wound in the scalp and a
fissured fracture on the left occipital region, which were necessarily mortal and which caused the
immediate death of the saidYu Lon. Defendant was found guilty of murder in the CFI, for which the
defendant made an appeal.

Issue: Whether or not a naturally resulting injury from a direct consequence of an unlawful act would
make theaggressor criminally liable.

Ruling:

Regarding the contention of the appellant that striking Yu Lon at the back of the headwould not possibly
cause him to fall forward on his face to the pavement, the Court declared upon expert testimony that
the victim had undergone a natural phenomenon of falling backwards on the pavement in an attempt to
regain balance. The Court referred to par. 1, Article 4 of the RPC which provides that criminal liability
shall be incurred by any person committing a felony (delito) although the wrongful act done be different
from what he intended; but in order that a person be criminally liable, thefollowing requisites must be
present: (1) that a felony was committed, and (2) that the wrong done tothe aggrieved person be the
direct consequence of the crime committed by the offender. There is no doubt as to the cause of the
death of Yu Lon, which occurred as the direct consequence of the blow dealt by the appellant.
People vs. Tomotorgo (April 30, 1985)

Facts: Accused was the husband of the deceased. She had been persistently asking her husband to sell
their conjugal home in order for them to transfer to the house of her husbands in-laws. Plaintiff didnt
want to abandon their house because the improvements that he made to the land.

Upon returning home one day, Accused found his wife and baby already gone. He went out to look and
managed to caught up with them. Plaintiff begged for his wife to surrender and when she refused, they
got into a fight when the plaintiff tried to take their child from his wife. The wife infuriated the accused
when she threw their child onto the grassy portion of the trail. Plaintiff picked up a wood and began
hitting his wife. She fell and complained of severe chest pains. Realizing what he had done, he brought
her home but she died despite plaintiffs effort to alleviate her pain.

Plaintiff brought the piece of wood and reported the incident to the baranggay where he was charged
with parricide and pleaded guilty. The court found him guilty of parricide but with three mitigating
circumstances. Appellant claims that the court handed him the wrong punishment. He avers that the
penalty for the felony committed by him parricide was higher than that which he intended to
commit physical injuries.

Issue: Whether the court imposed the wrong penalty.

Held: The judgment is affirmed but the court would recommend that executive clemency be extended
to the accused Article 4 of the RPC states that criminal liability shall be incurred by any person
committing a felony (delito) although the wrongful act be different from that which he intended and
that accused is liable for all the consequences of his felonious act. His lack of intention to commit a
grave wrong is at best mitigating.
People vs. Monleon December 10, 1946 (74 SCRA 263)

Facts:

On June 1, 1970, Cosme Monleon in his inebriated state asked whether the carabao was already fed. To
check the veracity of the statement, he went to see the carabao. He discovered that the carabao had
not been adequately fed. He was about to hit Marciano, his 10 year old son, when Concordia, his wife,
intervened. Monleon choked her, bashed her head against the post, and kicked her abdomen. Concordia
died the following day due to trauma or external violence.

Issue:

WON the accused is criminally liable although he had no intention to kill his wife.

Ruling:

Yes. Art 4 of the Revised Penal Code provides that criminal liability is incurred by any person committing
a felony although the wrongful act don be different than that which he intended to do. The
maltreatment inflicted by the accused on his wife was the proximate cause of her death. He could have
easily killed his wife had he really intended to take her life. He did not kill her outright. The accused was
found guilty of parricide sentencing him to reclusion perpetua.
US vs. Brobst 14 Phil 310

Facts:

Accused Brobst was the owner of a mining company. He discharged the deceased, his employee from
working in the mine because he was a thief. The deceased went back to look for work. Brobst was in the
tent ordered him off the place but deceased merely smiled or grinned at him. Accused approached him
and struck him a powerful blow with closed fist on the left side, just over the lower ribs, at the point
where his bolo's handle lay against his belt. The deceased threw up his hands, staggered and without
saying a word, went away in the direction of his sister's house where he died as he reached the door.
The trial court convicted him guilty of homicide. His defense contends that evidence fails to prove that
the blow was the cause of death.

Issue:

Whether or not accused is liable for the consequence of the death of his employee

Ruling:

Held: No. Under Art. 4 paragraph 1 of RPC result is different from what is intended is still punishable.
The Court takes note of the inflicted injury before death since there is no more proof that could lead to
the death of a person as there was no intervening cause.
People vs. Lucero 103 Phil. 500

Facts:

The accused Lucero was found guilty by the lower court of illegal possession of firearm. Lucero had been
appointed confidential agent and was authorized to possess a revolver to effect capture of one Angel
Aviso alias commander Mori.

Issue:

Whether or not accused Lucero is guilty of illegal possession of firearm.

Ruling:

The Court ruled that as the grant for the temporary use of revolver to defendant-appellant was a
necessary means to carry out a lawful purpose and within the limits of the law, defendant-appellant is
exempt from criminal liability for illegal possession of firearm.
Sulpicio Intod vs. CA G.R. 103119 October 21, 1992

Facts:
Sulpicio Intod, Jorge Pangasian, Santos Tubio and Avelino Daligdig went to Salvador Mandaya's
house and asked him to go with them to the house of Bernardina Palangpangan. Thereafter, they
had a meeting with Aniceto Dumalagan who told Mandaya that he wanted Palangpangan to be killed
because of a land dispute between them and that Mandaya should accompany them. Otherwise, he
would also be killed.
All of them armed arrived at Palangpangan's house and fired at Palangpangan's bedroom but there
was no one in the room. The Trial Court convicted Intod of attempted murder based on the testimony
of the witness.

Issue: Whether or not Intod is guilty attempted murder since it is an impossible crime under Art. 4
par. 2.

Ruling: Yes. The court held that the accused is guilty of impossible crime.

Art. 4 par. 2 provides that criminal liability is incurred:by any person performing an act which would
be an offense against persons or property, were it not for the inherent impossibility of its
accomplishment or on account of the employment of inadequate or ineffectual means.

Petitioner contends that, Palangpangan's absence from her room on the night he and his
companions riddled it with bullets made the crime inherently impossible. Legal impossibility occurs
where the intended acts, even if completed, would not amount to a crime
People vs. Gona 54 Phil. 605 March 15, 1930

Facts:

One evening, there was a reunion celebrated at the house of the Mansacas. Liberal supply of alcoholic
drinks resulted the men present to be intoxicated. A quarrel took place between one person and
defendant. Some of the people left the house, including the deceased and the defendant followed. But
because of the darkness of the night, the defendant mistook the one he was following for the deceased,
as he inflicted a mortal wound upon him. That he had no intention to kill the deceased because of
mistake, and alleges that he is only guilty of homicide through negligence.

Issue:

Whether or not mistake of the victim will relieve defendant from liability

Ruling:

The court held that his mistake in killing one man instead of another where it was proved that he acted
maliciously and willfully does not relieve him from criminal responsibility and could not even be
considered a mitigating circumstance.
US vs. Mallari 29 Phil. 14 December 23. 1914

Facts:

Accused Mallari went to the house of a married couple and threatened to kill them, alleging that they
enchanted his wife of an illness. He demanded the spouses to cure his wife, but rejected him because he
was not a wizard. The accused became enraged and pursued him, armed with a bolo. The deceased fled
away to report him to the authorities but the accused managed to caught up with him. The deceased
had no choice but to defend himself, but he was slashed by the accused in the abdomen and fled.

The victim developed infections in the wounds and died three days after. The accused was sentenced by
the trial court for homicide.

Issue:

Whether or not the accused is wholly liable for the consequences of his act.

Ruling:

Yes. Under Art. 4 of the RPC. The Court held that the proven perpetrator of a crime is directly
responsible for all the consequences of his criminal act, and therefore for the death that occurred five
days after the victim had received the wound that caused it.
People vs. Toling 62 SCRA 18 January 17. 1975

Facts:

Antonio Toling and Jose Toling twins, are illiterate farmers tilling their own lands. Antonio's daughter
works in Manila as well as Jose's three children. Antonio decided to go to Manila after receiving a letter
from his daughter telling him she would give him money. Jose decided to go with Antonio in order to see
his children. He was able to raise eighty-five pesos for his expenses. But when they reached the place all
the children gave him is only enough for their trip. After buying their tickets home, they boarded the
train in the afternoon. The train left in the evening. After a while, the twins ran amuck and started
stabbing the people in the coach. They were finally stopped when Constabulary soldiers aboard the train
heard about the incident.

The dead amounted to twelve. Eight suffered from stab wounds while others died after they jumped off
the train, apparently trying to escape the violence. The lower court found them guilty of multiple and
frustrated murder.

Issue:

Whether or not the two accused is also liable for the other deaths that were not caused by their
stabbing.

Ruling:

Yes. The court held that under criminal statutes, the presumption is that a person intends all the
consequences of his voluntary act. The rule is that if a man creates in another mans mind an
immediate sense of danger which causes such person to injure himself, the man who creates such state
is liable for the injuries which result.
US. Vs. Valdez 41 Phil. 497 March 22. 1921

Facts:

This is a case of homicide. The facts of the case are as follows: While the steamer Vigan anchored in
Pasig River, a small boat was sent to raise the anchor. The crew of the boat consisted of the accused and
among others the deceased. The accused was in charge of the men. The work of raising the anchor
seems to have proceeded slowly and the accused began to abuse the men with offensive remarks. The
deceased, remonstrated saying that they would work together if he would not insult them. The accused
took this as a display of insubordination and moved towards the deceased with a big knife. The
deceased believing himself in great peril, decided to jump to the water, but disappeared.

Issue:

Whether or not the victims act of jumping from the boat as a consequence, will result as a criminal
liability for the accused.

Ruling:

Yes. The Court held that If a person against whom a criminal assault is directed reasonably believes
himself to be in danger of death or great bodily harm and in order to escape jumps into the water,
impelled by instinct of self- preservation, the assailant is responsible for homicide in case death results
by drowning.
People vs. Quianson 62 Phil. 162

Facts:

The accused was convicted of homicide. In an occasion, the deceased went to ask for food where the
accused was preparing. The accused took hold of a fireband and applied it to the neck of the deceased
as he was repeatingly pestering him. The victim also received a wound in the abdomen from the
accused. While the deceased was undergoing medical treatment, the victim took out the drainage from
his wound and as a result, peritonitis developed and he died. The accused claimed that had not the
deceased taken out the drainage, he would not have died.

Issue:

Whether or not the acts of the victim on his wound that caused his death is the responsibility of the
accused.

Ruling:

Yes. The Court ruled that death was the natural consequence of the mortal wound inflicted. The victim,
in removing the drainage, did not do so voluntarily nor did he have knowledge that it was prejudicial to
his recovery. It was due to a pathological condition and state of nervousness and restlessness by the
victim on account of the physical pain caused by the wound.
People vs. Mabugat 51 Phil. 967

Facts:

The accused and Juana Buralo were sweethearts. One day, the accused invited Juana to take a walk with
him, but the latter refused him on account that the accused was seeing another woman. Later the
accused went to a house where Juana had gone to take part in some devotion. The accused waited for
Juana, with revolver in hand. Juana came out with her niece and proceeded to their house and the
accused followed them. As they were going upstairs, the accused shot at Juana but hit her niece instead.
She did not die because of proper medical attention.

Issue:

Whether or not the accused is liable for mistake of the person he intended to cause harm.

Ruling:

Yes. The Court held the accused guilty of frustrated murder, qualified by treachery, committed on the
niece of Juana.
People vs. Illustre 54 Phil. 594 March 14. 1930

Facts:

On St. Johns Day a celebration took place in a barrio, where a feast was held with a roasted pig. The
people considering of the presence of the pig, will try to take a piece of it. To direct the procession and
prevent the people from consuming the animal before it reached the end, defendant Ilustre was placed
in charge.

A young man, suffering from tuberculosis, tried to secure a piece of the pig, even though it was not
permitted. The defendant ran after him and boxed him as punishment, and the victim was sprawled on
the ground. Upon being struck the victim became very ill and was carried home, and in the afternoon he
expired. The opinion of a physician states that the cause of death was an internal hemorrhage in the
liver and although the victim had tuberculosis, he could not have died from it. Appellant was charged of
homicide.

Issue:

Whether or not Appellants blow on the victim, was the efficient cause of his death.

Ruling:

Yes. The court held that the deceased had a delicate constitution and suffered from tuberculosis does
not affect the criminal liability of the defendant. Even from his weakened condition rendered the blow
more fatal, the efficient cause of the death remains the same.
US vs. Rodriguez 23 Phil. 22 Aug 17, 1912

Facts:

Rosalino Rodriguez is charged for having dealt blows upon Marciano Magno, one on the stomach, and
one at the back. The witnesses averred that it was she (the accuseds daughter) that dealt the blows.
The physician observed on the autopsy, that the victim has suffered a weak heart and the wounds
developed abdominal peritonitis, all which hastened the death of the victim. The accused was convicted
for homicide.

Issue:

Whether or not the defendant is liable for the death of the victim.

Ruling:

Yes. The blows dealt by the accused to the victim is rightly classified as homicide if the victim dies as a
result. Even though, a blow of a fist or a kick does not produce external wound it may produce
inflammation of the spleen and peritonitis and cause death, and even though the victim was suffering
from an internal malady, yet a blow accelerated death, he who caused such is responsible for the death.
People vs. Reyes 61 Phil. 341

Facts:

Appellant was convicted by CFI in Camarines Sur of homicide. Appellant and deceased were a couple
that were scheduled to be married. One evening, on the occasion of the crime, there had been a barrio
procession. The deceased and appellant were talking outside the event. She informed him that she
could not return to him because of her parents. Appellant then dragged her towards the street and
stabbed her in the chest with a fan knife. The deceased managed to run towards the house of a barrio
lieutenant but fell dead at the foot of the staircase. Appellant contends that: (1) he was attacked by the
relatives of the deceased, and (2) he cannot be convicted with homicide because the wound inflicted
was superficial.

Issue:

Whether or not the wound inflicted by the accused is the proximate cause of death.

Ruling:

Yes. The Court held that a person is responsible for the consequences of his criminal act and even if the
deceased had been shown to be suffering from a diseased heart although not shown, appellants assault
being the proximate cause of the death, he would be responsible.
US vs. Marasigan 27 Phil 504

Facts:

Francisco Mendoza while examining his sugar crops was asked by the accused why the division line
between their lands was curved. They had a misunderstanding then suddenly, accused drew his knife to
strike him. A fight ensued and as a result, Mendoza sustained wounds where the one he got in his left
hand was the most serious. The accused assert he should have a new trial, to be given opportunity to
present evidence by submitting the victim to a surgical operation.

Issue:

Whether or not the victim, Mendoza, is obliged to submit to surgical operation.

Ruling:

No. The Court does not regard the case to warrant a new trial by alleged by the accused to show the
usefulness of the finger which was destroyed. Mendoza is not obliged to submit to surgical operation to
relieve the accused from the natural and ordinary results of his crime. It was his voluntary act which
disabled Mendoza and he must abide by the consequences resulting therefrom.
Vda. De Bataclan vs. Medina 102 Phil 181

Facts:

The case involves the overturning of a bus. Medina Transportation operated by its owner, defendant
Mariano Medina. The route of the bus on the tragic incident, was from Cavite to Pasay City. One of the
front tires burst and the vehicle began to zig-zag until it fell into a canal or ditch and turned turtle. Some
of the passengers managed to leave the bus while the others cannot. After a while, some men came
carrying lighted torches with them. But when they approached the bus, a fierce fire started because of a
gas leak that was due to the overturning of the bus, thus burning the passengers inside.

Issue:

What was the proximate cause of death of the passengers of the bus?

Ruling:

The court held that the overturning of the bus was the proximate cause of death. That a vehicle turned
on its back, the leaking of the gas from the tank was not unnatural or unexpected. That the coming of
the men with the torches was expected in a rural area where lanterns and flashlights were unavailable.
The driver was accountable to the consequence as a result of his negligence.
People vs. Martin 89 Phil. 18

Facts:

Accused was convicted with the complex crime of parricide with abortion. The accused was woken up by
his wife and told him why he doesnt have interest in her anymore. He said that he doesnt love her and
he consented to marry her only because of fear of her filing against him. Accused had to answer the call
of nature, but then his wife came after him with a rope placed around his neck. He asked as to why, and
she said because he does not love her. Accused managed to took off the rope and turned the same to
his wife and tightened it, thus killing her, and her unborn child because she was pregnant.

Issue:

Whether or not accused is proximately liable for the death of his wife

Ruling:

Yes. The Court reiterated their rule in People vs. Reyes: that a person is responsible for the
consequences of his criminal act and even if the deceased had been shown to be suffering from a
diseased heart although not shown, appellants assault being the proximate cause of the death, he
would be responsible.
People vs. Piamonte 94 Phil. 293

Facts:

The accused was charged with robbery with homicide. A robbery took place in the house of one Magno
Israel. In the course of the robbery, he was seriously wounded and was taken to a hospital for
treatment. The operation did him well but not so in the post-operative period, where he contracted a
sickness known as mucuous colitis which develop due to his weak condition and died afterwards.

Issue:

Whether or not the deceased died as a result of the wounds inflicted upon him by the accused, that he
was able to survive for sometime because of the operation.

Ruling:

Yes. The Court affirm the statements of the doctors who attended the deceased had agreed that the
weakened condition which caused disturbance of the functions of the intestines made it possible for him
to contract mucuous colitis, which shows that while said wounds were not the immediate cause, they
were however the proximate cause of death.
Gumabon v. Director of Prisons 37 SCRA 420

Facts:

Gumabon, after pleading guilty, was sentenced to reclusion perpetua for the complex crime of rebellion
with multiple murder, robbery, arson and kidnapping (along with Agapito, Palmares and Padua). Each of
the petitioners have been imprisoned for more than 13 years by virtue of their convictions.

They now invoke the doctrine laid down in People v. Hernandez which negated such complex crime, a
ruling which was not handed down until after their convictions have become final. In People v.
Hernandez, the SC ruled that the information against the accused for rebellion complexed with murder,
arson and robbery was not warranted under Art. 134 of the RPC, there being no such complex offense.
This ruling was not handed down until after their convictions have become final. Since Hernandez served
more than the maximum penalty that could have been served against him, he is entitled to freedom,
and thus, his continued detention is illegal.

Issue:

Whether or not Art. 22 of the RPC which gives a penal judgment a retroactive effect is applicable in this
case, that judicial decisions favourable to the accused/convicted for the samecrime can be applied
retroactively.

Ruling:

Yes. Judicial decisions favourable to the accused must be applied retroactively. Petitioners relied on Art.
22 of the RPC, which states the penal laws shall have a retroactive effect insofar as they favour the
accused who is not a habitual criminal. The Civil Code also provides that judicial decisions applying or
interpreting the Constitution forms part of our legal system. Petitioners even raised their constitutional
right to equal protection, given that Hernandez et al., has been convicted for the same offense as they
have, though their sentences were lighter. Habeas corpus is the only means of benefiting the accused by
the retroactive character of a favorable decision
People vs. Narvaez, 121 SCRA 389 (1983)

Facts:

Mamerto Narvaez has been convicted of murder (qualified by treachery) of David Fleischer and Flaviano
Rubia. Narvaez shot Fleischer and Rubia during the time the two were constructing a fence that would
prevent Narvaez from getting into his house and rice mill. The defendant was taking a nap when he
heard sounds of construction and found fence being made. He addressed the group and asked them to
stop destroying his house and asking if they could talk things over. Fleischer responded with "No,
gadamit, proceed, go ahead." Defendant lost his "equilibrium," and shot Fleisher with his shotgun. He
also shot Rubia who was running towards the jeep where the deceased's gun was placed. Prior to
theshooting, Fleischer and Co. (the company of Fleischer's family) was involved in a legal battle with the
defendant and other land settlers of Cotabato over certain pieces of property. Defendant claims he
killed in defense of his person and property. CFI ruled that Narvaez was guilty.

Issue:

Whether or not the court erred in convicting defendant-appellant although he acted in defence of his
rights.

Ruling:

Yes. However, the argument of the justifying circumstance of self-defense is applicable only if the 3
requirements are fulfilled but the indispensable requisite being Unlawful aggression. In the case at bar,
there was unlawful aggression towards appellant's property rights. In Reasonable necessity of means
employed to prevent or repel attack. In the case, killing was disproportionate to the attack. Lack of
sufficient provocation on part of person defending himself. Here, there was no provocation at all since
he was asleep.

Gutierrez, dissenting. Defense of property can only be invoked when coupled with form of attack on
person defending property. In the case at bar, this was not so. Appellant should then be sentenced to
prision mayor. However, since he has served more than that, he should be released.
In Re: Kay Villegas Kami, 35 SCRA 429 (1970)

Facts:

Kay Villegas Kami Inc. claiming to be a recognized nonstock, non-profit corporation contests validity of
RA # 6132 Sec. 8 saying it violates due process rights of association, freedom of expression and is an ex
post facto law

Issue:

Whether or not it is an ex post facto law?

Ruling:

No. Ex post facto law defined:

a. makes criminal an act done before law was passed and punishes act innocent when done.
b. aggravates a crime, makes it greater than it was.
c. inflicts greater punishment than the law prescribed when committed.
d. alters legal rules of evidence and authorizes conviction upon less or different tests.
e. assuming to regulate civil rights and remedies only in effect imposes penalty or deprivation of right
which when done was lawful.

Constitutional inhibition refers only to criminal laws. Penalty in law imposed to acts committed after
approval of law. Petition denied.
People vs. Ringor, 320 SCRA 342 (1999)

Facts:

The accused (Ringor) on the night of June 23, 1994 was seen entering a restaurant. A witness Fely
Batanes saw the accused approach a table where the victim was sitting, pulled his hair, and poked a
knife at the latters throat. After, leaving the restaurant, the accused returned with a gun, entered the
kitchen of the restaurant, stealthily approached the victim from behind and shot him six times
successively. The defendant was later apprehended and caught in his possession was an unlicensed
weapon. Ringor put up self-defense but he failed to prove Floridas unlawful aggression. He was found
guilty of murder qualified by treachery and was sentenced to death. He was found guilty of a separate
charge of possession of an unlicensed firearm with a sentence of 17 to 20 years.

Issue:

Whether or not RTC erred in convicting appellant for simple illegal possession of firearms and sentenced
him to suffer an indeterminate sentence of 17 to 20 years.

Ruling:

Yes. In cases where murder or homicide is committed with the use of an unlicensed firearm, there can
be no separate conviction for the crime of illegal possession of firearms under PD No. 1866. t is simply
considered as an aggravating circumstance, no longer as a separate offence.
According to the article 22 of RPC, retroactivity of the law must be applied if it is favourable to the
accused.
People vs. Pimentel, 288 SCRA 542 (1998)

Facts:

In 1983, Tujan was charged with subversions under RA 1700 with warrant of arrest issued. On June 5,
1990, Tujan was arrested and caught with .38 caliber revolver. On June 14, 1990, he was charged with
illegal possession of firearms and ammunition in furtherance of subversion (PD 1866) Tujan filed motion
to quash invoking protection versus double jeopardy (Art. III, Constitution; Misolas v. Panga; and Enrile
v. Salazar: alleged possession absorbed in subversion.) It was granted by the trial court and the court of
appeals.

Issue:

Whether or not charge under PD 1866 be quashed on ground of double jeopardy in view of the previous
charge under RA 1700.

Ruling:

No.
1. Article III of the Constitution and Rule 117 Revised Rules of Court state that for double jeopardy to
occur, acquittal, conviction or dismissal in previous cases must have occurred. In this case, first case was
not even arraigned yet.
2. They are different offenses. R.A. 1700 punishes subversion while PD 1866 punishes illegal possession
of firearms.

However, since RA 7636 totally repealed subversion or RA 1700, and since this is favorable to the
accused, we can no longer charge accused with RA 1700 even if they didnt raise this issue. PD 1866
should be amended to mere illegal possession of firearms without furtherance of subversion

Ruling: RTC and CA reversed and set aside. RA 1700 charge dismissed. PD 1866 change amended.
Release Tujan.