U.S. v. Apostol 14 Phil.

92 September 2, 1909 CJ Arellano

FACTS: On December 16, 1907, there were five individuals, including Catalino
Apostol, who went to the house of Pedro Tabilisima, Celestino Vergara, and
Tranquilino Manipul to inquire about their missing carabaos. After Tabilisima,
Celestino Vergara, and Tranquilino Manipul said that they knew nothing about
it, Catalino Apostol told them to leave the house. However, they refused to do
so. Thus, Catalino set fire to the hut and the same was burnt down. According
to the trial court, the testimonies of the injured party provided sufficient
evidence to prove the responsibility of the accused. Therefore, Catalino was
proven to have committed the acts within the provisions of article 549 of the
Penal Code. He sentenced to sixteen years and one day of
cadena temporal. And he ordered to indemnify the value of the burnt hut worth
1 pesos. Catalino then appealed to this Court with the following defense: 1.
There was absence of proof of intent. 2.
The fact that the burnt house was situated in an uninhabited place, it is
improper to apply Art 549 instead Art 554 of the Penal Code should be applied.

ISSUE: Whether or not proof of intent is needed?

HELD: No. As provided in Art 1 Penal Code, Criminal intent as well as the will
to commit a crime are always presumed to exist on the part of the person who
executes an act which the law punishes, unless the contrary shall appear. In
the case, there was no need to prove the intent of Catalino for committing the
act. As intent is largely a mental process, there is always a presumption of
intent arising from overt acts. 2.