PLS ADD NOTES IF EVER NAA SOMETHING

FELONIES

A. Preliminary Matters

1. Differentiating Felonies, Offenses, Misdemeanors and Crimes

Felonies
- refers to violations of the RPC
- kidnapping, arson, assault

Offenses
- crime punished under a special law (statutory offense)
- battery, robbery, drug possession

Misdemeanors
- minor infraction of the law such as violation of an ordinance
- trespassing, reckless driving, shop lifting

Crimes
- whether the wrongdoing is punished under RPC or under a special law
- the word generic crime can be used

2. Classification of Felonies (according to manner of their commission; nature;

stages of their execution; gravity; count)

Elements of Felonies:
1. There must be an ACT or OMISSION.
2. The act or omission must be PUNISHABLE by the RPC.
3. The act is performed or the omission incurred by means of DOLO or CULPA.

• People vs. Gonzales, GR No. 80762, Mar. 19, 1990 (page 41)
(that the act is performed or the omission incurred by means of dolo or culpa)
(KATONG GULANG NI PATAY SA AMO NGA GI APIL SA WITNESS)

Facts:
The case involves the killing of Lloyd Peacerrada on February 21, 1981, in Barangay Tipacla,
Ajuy, Iloilo. The accused are Fausta Gonzales, Augusto Gonzales, Custodio Gonzales, Sr.
(appellant), Custodio Gonzales, Jr., Nerio Gonzales, and Rogelio Lanida. The incident was
reported by Augusto and Fausta Gonzales, who surrendered to Barangay Captain Bartolome
Paja and were subsequently taken into police custody. The victim was found with multiple stab
and incised wounds. An autopsy revealed 16 wounds, five of which were fatal. The Regional
Trial Court of Iloilo found all the accused guilty of murder and sentenced them to imprisonment
and to indemnify the victim's heirs. Custodio Gonzales, Sr. appealed the decision, but the Court
of Appeals modified the sentence to reclusion perpetua and certified the case to the Supreme
Court. The prosecution's case relied heavily on the testimony of Jose Huntoria, who claimed to
have witnessed the crime but only came forward eight months later. The defense argued that
Huntoria's testimony was unreliable and that Custodio Gonzales, Sr. was not involved in the
crime. The Supreme Court found the evidence insufficient to convict Custodio Gonzales, Sr. and
acquitted him.

Issue:
1. Was the testimony of Jose Huntoria sufficient to establish the guilt of Custodio Gonzales,
Sr. beyond reasonable doubt?
2. Was the defense of alibi presented by Custodio Gonzales, Sr. credible and exculpatory?

Ruling:
1. The Supreme Court ruled that the testimony of Jose Huntoria was not sufficient to
establish the guilt of Custodio Gonzales, Sr. beyond reasonable doubt.
2. The Supreme Court found the defense of alibi presented by Custodio Gonzales, Sr.
credible and exculpatory under the circumstances.

Ratio:
The Supreme Court emphasized that the prosecution failed to provide specific evidence linking
Custodio Gonzales, Sr. to the fatal wounds inflicted on Lloyd Peacerrada. The court noted that
Huntoria's testimony lacked specificity regarding the actions of Custodio Gonzales, Sr., and that
there was no evidence proving his direct participation in the crime.

Additionally, the court found Huntoria's credibility questionable due to his delay in
reporting the incident and his potential bias as a tenant of the victim. The court also
considered the improbability of a 65-year-old man participating in such a violent act,
given Filipino customs and traditions.

Finally, the court acknowledged that while alibi is generally a weak defense, it can be
exculpatory when the evidence against the accused is not compelling. In this case, the lack of
concrete evidence and the credible alibi led to the acquittal of Custodio Gonzales, Sr.

• People vs. Silvestre, GR No. 35748, Dec. 14, 1931

(SUNOG NGA KABALO SIYA PERO PA WALAY CARE)

Facts:
The case involves the People of the Philippine Islands as the plaintiff-appellee against Romana
Silvestre and Martin Atienza, the defendants-appellants. The events took place in the barrio of
Masocol, municipality of Paombong, Province of Bulacan. On May 16, 1930, Romana Silvestre
and Martin Atienza were arrested for adultery following a complaint filed by Silvestre’s husband,
Domingo Joaquin.
The case was initially dismissed after the accused promised to cease their relationship and
leave the barrio. However, they returned to Masocol in November 1930. On the night of
November 25, 1930, Atienza, armed with a pistol, declared his intention to burn down a house
as revenge against the barrio residents who had instigated the adultery charges. The fire he set
resulted in the destruction of forty-eight houses. Witnesses saw Atienza leaving the scene and
Silvestre nearby. The Court of First Instance of Bulacan convicted Atienza as the principal by
direct participation in arson and sentenced him to fourteen years, eight months, and one day of
cadena temporal. Silvestre was convicted as an accomplice and sentenced to six years and one
day of presidio mayor. Both were ordered to pay damages to the affected residents.

Issue:
1. Did the lower court err in convicting Romana Silvestre as an accomplice to the crime of
arson?
2. Should Romana Silvestre be acquitted due to insufficient evidence or reasonable doubt?

Ruling:
1. The Supreme Court reversed the conviction of Romana Silvestre, acquitting her of the
charges.
2. The conviction of Martin Atienza for arson was affirmed.

Ratio:
The Supreme Court found that mere passive presence at the scene of a crime, silence, and
failure to give an alarm do not constitute the cooperation required for complicity under Article 14
of the Penal Code. For complicity, there must be evidence of moral or material cooperation or
an agreement to commit the crime. In Silvestre’s case, there was no such evidence. Her silence
and passive presence did not encourage or aid Atienza in committing arson. Therefore, she
could not be held liable as an accomplice. On the other hand, Atienza’s actions clearly
constituted arson under Article 550, paragraph 2 of the Penal Code, as he set fire to an
inhabited house, resulting in the destruction of other houses without knowing whether they were
occupied, thereby endangering lives.

B. Manner of Incurring Criminal Liability [Art. 3, RPC]

B.1. Dolo vs. Culpa; Requisites of Dolo or Culpa

Intentional Felonies, the act or omission is malicious. It has the deliberate intent to cause an
injury to another. Culpable Felonies, the act or omission is NOT malicious. The act is
unintentional which results from imprudence, negligence, lack of foresight or lack of skill.

Dolo: means malice (deceit) which is the intent to do an injury to another

Culpa: means fault

Requisites for Dolo or Malice

1. He must have FREEDOM while doing or omitting the act;
2. He must have INTELLIGENCE while doing or omitting the act; and
 3. He must have INTENT while doing or omitting the act

1. Intentional Felonies (Mistake of fact)

Requisites for Mistake of Fact as a Defense

1. The act done would have been lawful had the facts been as the accused believed them
to be;
2. That the intention of the accused in performing the act should be lawful; and
3. That the mistake must be without fault or carelessness on the part of the accused.

How to determine if a felony is intentional?

- there is deliberate intent in the commission of a felony if the offender, in doing the act or
omitting to do an act, has done so with FREEDOM, INTELLIGENCE and INTENT

• Ah Chong and Oanis cases (page 54, RPC)

(GI DUNGGAB ANG ROOMMATE) & (WRONG SEND ANG PAG PUSIL)

Ah Chong
- Ah Chong was acquitted because of a mistake of fact.
- Article 11 (par. 1), RPC requires to justify the act, that there be:
a. unlawful aggression on the part of the person killed
b. reasonable necessity of the means employed to prevent or repel it
c. lack of sufficient provocation on the part of the person preventing himself.
- if intruder forced his way to the room, there would be unlawful aggression on the part of
the intruder
- there is a necessity for Ah Chong to defend himself
- knife would have been a reasonable means to prevent or repel such aggression
- Ah Chong gave no provocation

Oanis
- wrong person
- both accused are guilty of murder

• Diego vs. Castillo, A.M. No. RTJ-02-1673, Aug. 11, 2004

(FOREIGN MINYO)

Facts:
The case "Diego v. Castillo" involves an administrative complaint against Judge Silverio Q.
Castillo of the Regional Trial Court, Dagupan City, Branch 43. The complaint was filed by
Eduardo P. Diego, the brother of Manuel P. Diego, who married Lucena Escoto on June 4,
1987. Lucena Escoto had previously married Jorge de Perio, Jr. on January 9, 1965, under the
name Crescencia Escoto. On February 15, 1978, a Decree of Divorce was issued by the Family
District Court of Harris County, Texas, dissolving the marriage between Jorge de Perio and
Crescencia de Perio. Despite this, Lucena Escoto married Manuel P. Diego, presenting herself
as single.

The criminal case for bigamy was tried, and on February 24, 1999, Judge Castillo acquitted
Lucena Escoto, citing her good faith belief that her first marriage had been legally
dissolved by the foreign divorce decree.

The complainant, Eduardo P. Diego, argued that the decision was contrary to law and evidence,
questioning the admissibility and weight of the divorce decree as evidence of good faith.
He sought sanctions against Judge Castillo for knowingly rendering an unjust judgment
and gross ignorance of the law.

Issue:
1. Did Judge Silverio Q. Castillo knowingly render an unjust judgment in the bigamy case?
2. Did Judge Castillo exhibit gross ignorance of the law in his decision to acquit Lucena
Escoto?

Ruling:
1. The court found no basis for the charge of knowingly rendering an unjust judgment
against Judge Castillo.
2. The court found Judge Castillo guilty of gross ignorance of the law and imposed a fine of
Ten Thousand Pesos (P10,000) with a stern warning against future similar acts.

Ratio:
The court examined whether Judge Castillo knowingly rendered an unjust judgment and found
that for such a charge to hold, it must be shown that the judgment was unjust and made with
conscious and deliberate intent to do an injustice. The court concluded that there was no
evidence of bad faith, malice, or corrupt purpose on the part of Judge Castillo.

However, regarding the charge of gross ignorance of the law, the court noted that Judge
Castillo's decision was based on a mistaken belief that a foreign divorce decree could dissolve a
marriage between Filipino citizens, which is not recognized under Philippine law. The court cited
precedents, including People v. Bitdu and People v. Schneckenburger, which established that a
mistake of law does not excuse criminal liability for bigamy. The court emphasized that judges
must exhibit due care in their adjudicatory functions and that gross ignorance of the law
warrants disciplinary action. Given the gross and patent error in Judge Castillo's decision, the
court imposed a fine and issued a stern warning for future conduct.

• Yapyuco vs. Sandiganbayan, GR No. 120744-46, June 25,

2012
(WRONG SEND NGA SHOOTING SA SAKYANAN)

Facts:
The case "Yapyuco y Enriquez v. Sandiganbayan" revolves around a shooting incident that
occurred on April 5, 1988, in Barangay Quebiawan, San Fernando, Pampanga. This incident
resulted in the death of Leodevince Licup and the injury of Noel Villanueva. The accused in this
case included members of the Integrated National Police (INP), barangay captains, barangay
tanods, and Civil Home Defense Force (CHDF) officers. They faced charges of murder,
frustrated murder, and multiple counts of attempted murder. The Sandiganbayan found the
accused guilty, determining that they acted with treachery and evident premeditation. The
court's decision was heavily based on witness testimonies and forensic evidence.

The accused were alleged to have fired at a green Toyota Tamaraw jitney, leading to Licup's
death and Villanueva's injuries. All the accused, except for Pabalan who had died earlier,
entered pleas of not guilty. The Sandiganbayan granted bail to some of the accused and
dismissed charges against Pamintuan following his death. The prosecution successfully
established that the victims were unarmed and were fired upon without any warning. In their
defense, the accused claimed they were acting in the performance of their duties, responding to
a report of armed men. However, the Sandiganbayan concluded that the accused exceeded
their duties and acted with intent to kill, finding them guilty of homicide and attempted
homicide, while acquitting them of multiple attempted murder.

Issue:
1. Did the accused act in the regular and lawful performance of their duties?
2. Was there a conspiracy among the accused to commit the crimes charged?
3. Were the accused guilty of murder, frustrated murder, and multiple counts of attempted
murder?

Ruling:
1. The Sandiganbayan found the accused guilty of homicide and attempted homicide,
acquitting them of multiple attempted murder.
2. The court ruled that the accused conspired to commit the crimes charged.
3. The accused were sentenced to suffer penalties ranging from six months to twelve years
and were ordered to indemnify the victims' heirs and the injured party.

Ratio:
The court held that the accused acted with deliberate intent to kill under the guise of maintaining
peace and order. The evidence presented showed that the accused fired at the victims without
sufficient basis or probable cause to believe they were armed rebels. The court found that the
accused exceeded their duties and resorted to unnecessary violence. The testimonies of
witnesses and forensic evidence supported the conclusion that the accused conspired to
commit the crimes.

The court rejected the defense of lawful performance of duty and mistake of fact,
determining that the accused acted with criminal intent. Additionally, the court noted the
absence of any real threat or aggression from the victims that would justify the use of deadly
force. Consequently, the court modified the penalties and damages awarded, affirming the
Sandiganbayan's decision with modifications.

(art. 11 sec 5 - defense of katong nag pusil)

2. Culpable felonies
In culpable felonies, criminal intent is replaced by negligence and imprudence.

- crimes or offenses that have been committed through the fault of one person.
- there is no intention to harm others but the harm was still done either through
negligence, lack of skill, or even through the ignorance of the law
- no criminal intent in the mind of the offender but his acts or omissions are still punishable
by law because of the damages and injuries caused to others as a result of his
negligence, imprudence, lack of skill or lack of foresight.

Imprudence
- usually involves lack of skill
- deficiency of action or failure to take necessary precaution to avoid injury or damage (ex.
when a driver fails to check and determine the road worthiness of his vehicle before
hitting the road where thereafter he had a brake failure which caused him to run over a
pedestrian.)
Negligence
- usually involves lack of foresight.
- deficiency of perception or failure to pay proper attention and to use diligence to avoid a
foreseeable damage or injury (ex. when a cop indiscriminately fires his gun in the air
during New Year’s Eve which caused injury to another)

Requisites of CULPA
1. He must have FREEDOM while doing or omitting the act;
2. He must have INTELLIGENCE while doing or omitting the ac; and
3. Imprudent, Negligent, Lack of foresight or lack of skill

3. Felonies punished under special laws

- Crimes punished by municipal or city ordinances
- Intent to commit a crime is not necessary
- Intent to perpetrate the act prohibited by special law is sufficient
- In those crimes punished by special laws, the act alone, irrespective of its motives,
constitutes the offense.
Intent to perpetrate the act
- Prohibited act is done freely and consciously
Good faith and absence of criminal intent not valid defenses in crimes punished by Special
laws.
Mala in se - evil in itself
- inherintly immoral (rape, arson murder)
- Wrongful from their nature

When acts are inherently immoral, they are mala in se even if they are punished under special
law.

Mala prohibita - prohibited

- Wrong merely because prohibited by statute
- Acts made criminal due to Special laws
- not necessarily immoral
- crimes of ommission

Motive
- The desire to do a certain action
- Moving power which impels one to action for a definite result
Intent
- The specific means to carry the act
- Purpose to use a particular means to effect such result

B.2. Error in Personae/Aberratio Ictus/Praeter Intentionem [Art. 4, RPC]

Error in Personae
- Mistake in the identity

Aberratio Ictus
- Mistake in the blow

Praeter Intentionem
- Injurious result is greater than that intended

• People vs. Bindoy, 56 Phil. 15 (page 71)

- ga away sila tungod gi lugos ug tagay ni bindoy ang asawa ni pacas.
- nag threat si bindoy nga mag “injure” sha sa asawa.
- ga lalis si bindoy ug ang asawa. kita si pacas, nag pa hero sha nga kuhaon niya ang
bolo ni bindoy (basun unyag ma dugsakan iyang asawa gg).
- si omamdam naki chismis marites. unya while ga fight2 sila ni bindoy ug pacas para sa
bolo, imbis nga si pacas ang dugsakon ni bindoy.. ang na dugsak is si omamdam. of
course, wa kabalo si bindoy nga naki chismis ra diay si omamdam
- there is no evidence to show that Bindoy deliberately injured Omamdam (with intent).
Bindoy was only defending for the position of the bolo. Bindoy should be acquitted.
(art. 8 & art. 12;par. 4 - legal basis)

• People vs. Cagoco, 58 Phil 524

(GR No. 38511, Oct. 6, 1933)
(Praeter Intentionem)

Facts:
In the case of "People vs. Cagoco," Francisco Cagoco y Ramones, also known by several
aliases including Francisco Caguro and Bucoy, was charged with the crime of asesinato
(murder) for the death of Yu Lon. The incident occurred on July 24, 1932, in the City of Manila,
specifically at the corner of Mestizos and San Fernando Streets in the District of San Nicolas.
On that evening, Yu Lon and his son, Yu Yee, were conversing on the sidewalk when Cagoco,
who had been passing back and forth behind them, suddenly struck Yu Lon on the back of the
head with his fist. This unexpected blow caused Yu Lon to fall, resulting in a lacerated wound
and a fissured fracture in the occipital region of his skull, leading to his immediate death. The
trial in the Court of First Instance of Manila, presided over by Judge Luis P. Torres, found
Cagoco guilty of murder and sentenced him to reclusion perpetua, along with accessory
penalties, indemnification of the heirs of the deceased in the sum of P1,000, and payment of the
costs. Cagoco's defense raised several assignments of error, primarily contesting his
identification as the assailant and the classification of the crime as murder rather than
maltreatment.

Issue:
1. Did the trial court err in identifying Francisco Cagoco as the assailant of Yu Lon?
2. Did the trial court err in finding that Cagoco struck Yu Lon?
3. Did the trial court err in determining that the blow was dealt from behind?
4. Was the identity of Cagoco as the assailant fully established?
5. Should Cagoco be convicted of murder under Article 248 of the Revised Penal Code, or
should he be convicted of maltreatment under Article 266?

Ruling:
1. The Supreme Court upheld the trial court's identification of Francisco Cagoco as the
assailant.
2. The Court affirmed that Cagoco did strike Yu Lon.
3. The Court agreed with the trial court's finding that the blow was dealt from behind.
4. The Court found that the identity of Cagoco as the assailant was fully established.
5. The Court ruled that Cagoco was correctly convicted of murder under Article 248 of the
Revised Penal Code, but modified the prison sentence to seventeen years, four months,
and one day of reclusion temporal due to the presence of a mitigating circumstance.

Ratio:
The Supreme Court found no sufficient reason to doubt the trial court's findings regarding the
identification of Cagoco as the assailant. The testimonies of Yu Yee and two other Chinese
witnesses, Chin Sam and Yee Fung, were deemed credible. Despite some minor
inconsistencies in the description of Cagoco's facial features, the immediate and confident
identification of Cagoco by Yu Yee at the police station was compelling. The Court also
considered the corroborative testimony of a 15-year-old boy, Dominador Sales, who witnessed
the incident.
Regarding the nature of the crime, the Court emphasized that the death of Yu Lon was the
direct consequence of Cagoco's felonious act of striking him on the head. Even though Cagoco
did not intend to kill Yu Lon, the act was committed with treachery, as it was sudden and without
warning, ensuring the accomplishment of the assault without risk to Cagoco. This qualified the
crime as murder under Article 248 of the Revised Penal Code. The Court also noted that the
mitigating circumstance of not having intended to cause so great an injury was applicable, which
warranted a reduction in the prison sentence.
The Court cited relevant jurisprudence, including the U.S. vs. Brobst and U.S. vs. Candelaria
cases, to support its decision. These cases established that criminal liability is incurred for the
natural consequences of one's illegal acts, even if the specific outcome was not intended. The
presence of treachery in the manner of execution further solidified the classification of the crime
as murder.

• People vs. Rodriguez, 23 Phil 22

[G.R. No. 7123. August 17, 1912. ]

THE UNITED STATES, Plaintiff-Appellee, v. ROSALINO RODRIGUEZ, Defendant-Appellant.

G. E. Campbell for Appellant.

Attorney-General Villamor for Appellee.

SYLLABUS

1. HOMICIDE; CRIMINAL RESPONSIBILITY. — When the fact is well established that the accused struck the victim
twice with his fist, in the abdomen and in the back, wherefore the latter fell to the ground and had hardly risen and
started to walk when he again fell down dead, the crime committed is rightly classified as homicide and the accused
is responsible therefor.

2. ID.; ID. — Even though a blow with the fist or a kick does not cause any external wound it may easily produce
inflammation of the spleen and peritonitis and cause death, and even though the victim may have been previously
affected by some internal malady, yet if a blow with the fist or foot accelerated death, he who caused such
acceleration is responsible for the death as the result of an injury willfully and unlawfully inflicted.

3. ID.; ID.; EXTENUATING CIRCUMSTANCES. — It is plain in such a case as this that the accused did not mean to
inflict so grave an injury as he did. It is also plain from the very text of the complaint and the statement of the fiscal
that the motive for the assault was that the accused saw the deceased seize his daughter’s hand to make love to her,
which constitutes immediate provocation on the victim’s part. The presence of these two well-defined extenuating
circumstances and the absence of any aggravating one make proper the application of rule 5 of article 81 of the
Penal Code and the imposition of the penalty next lower than that prescribed by the law.

DECISION
 ARELLANO, C.J. :

Rosalino Rodriguez is charged with having dealt Marciano Magno two blows with the fist, one on the left side toward
the stomach and the other on the back, which knocked him down. He got up by the assistance of two witnesses who
were present at the time of the occurrence and by their aid endeavored to return to his home, which he did not reach,
for the reason that, having gone a distance of twenty brazas from the place, he again fell to the ground, this time
dead.

Two witnesses testified to having seen the defendant strike those two blows.

The following were offered by the defendant as defenses: chanrob1es virtual 1aw library

(1) The testimony of his daughter and two other witnesses;

(2) the fact that his right hand was disabled; and (3) the medical certificate issued by a physician as a result of the
autopsy.

The defendant’s daughter averred that it was she who struck Marciano Magno the blow with the fist, for the reason
that the deceased had caught hold of her hand with unchaste designs, and testified that her father arrived after
Magno had fallen to the ground, which testimony was supported by two witnesses.

This defense was not sustained by the trial judge. But on the contrary, he accepted the preponderance of evidence
for the prosecution, sustained by three witnesses, of whom two were eyewitnesses to the crime, and the other, of the
confession alleged to have been made to him by the defendant when arrested by this witness, to the effect that the
victim’s death was an unlooked-for misfortune.

Nor was the defense advanced by the defendant to the effect that his right hand was crippled and he was unable to
work with it sustained by the trial court, and rightly, since, as the defendant testified, he worked with his left hand and
sometimes used a spoon with his right; moreover, it was proved that it was impossible for him to strike blows with
either hand.

The defense founded on the medical examination of the corpse consists in that the physician who made the autopsy
declared that he had observed hypertrophy of the heart, a discharge in the spleen, an increase of this latter organ to
four times its ordinary size, and abdominal peritonitis; and in that, according to this examination, the cause of death
can not be determined for the blows which he may have received could have coincided with the traumatism, and "the
traumatisms which that body received hastened the death of the said individual;" and, finally, this witness being
questioned by the defense as to whether the cause of death was a traumatism or a shock, replied that he was unable
to determine which it was.

As was proper, neither was this defense sustained by the trial judge. The defendant was, therefore, found guilty of the
crime of homicide and sentenced to twelve years and one day of reclusion temporal, to the accessory penalties and
an indemnity of P1,000 to the heirs of the deceased, and to the payment of the costs; from which judgment he
appealed.

This appeal, forwarded from the Court of First Instance of Nueva Ecija, having been heard, together with the
allegations and arguments therein made by the parties, whereby it appears to have been well proven that the
defendant did strike Marciano Magno in the abdomen and in the back two blows with his hand, as a result of which
the latter fell to the ground, and scarcely had he gotten up and started to walk when he fell down dead, we hold that
the crime is properly classified as homicide and that Rosalino Rodriguez is responsible therefor.
A blow with the fist or a kick, though causing no external wound, may very well produced inflammation of the spleen
and peritonitis and cause death; and although the assaulted party was previously affected by some internal malady,
if, because of a blow given with the hand or the foot, his death was hastened, beyond peradventure he is responsible
therefor who produced the cause for such acceleration as the result of a voluntary and unlawfully inflicted injury.

But in the complaint itself it is alleged that the cause of the assault was the fact that the defendant saw the deceased
catch hold of his daughter Roberta’s hand, for the purpose of making love to her, and the provincial fiscal stated at
the trial that this assertion was the result of a careful investigation made by him, which was indeed confirmed by the
facts proven.

It therefore appears that the defendant’s act was preceded by an immediate provocation on the part of the deceased,
and, evidently, the defendant did not intend to cause so grave an injury as he produced.

With the existence of these two well-defined extenuating circumstances and without any aggravating circumstance,
rule 5 of article 81 of the Penal Code must be applied and the penalty immediately inferior to that fixed by law
imposed. Consequently, modifying the penalty imposed by the lower court to eight years and one day of prision
mayor, the judgment appealed from is affirmed, with the costs of this instance against the Appellant. So ordered.

Mapa, Johnson, Carson, and Trent, JJ., concur.

• People vs. Reyes, 61 Phil 341

(GR No. 42117, Mar. 29, 1935)

Facts:
The case of People v. Reyes involves the conviction of Gregorio Reyes for the crime of
homicide committed on Fausta Tavera. The incident occurred on the evening of April 30, 1934,
in Camarines Sur, Philippines. Prior to the crime, the deceased had been living with the
defendant for a couple of weeks, but her parents persuaded her to come home and demanded
a dowry from the defendant. On the evening of the incident, the defendant stabbed the
deceased in the chest with a fanknife after she informed him that she could not return to him.
The deceased ran to a nearby house and died from shock as a result of the wound.

Issue:
The main issue raised in the case is whether the defendant, Gregorio Reyes, should be held
guilty of homicide for the death of Fausta Tavera.

Ruling:
The court ruled that the defendant, Gregorio Reyes, is guilty of homicide.

Ratio:
The court held that the defendant is responsible for the consequences of his act, even if the
deceased had a pre-existing health condition. The court emphasized that when a person stabs
another with a lethal weapon in a vital part of the body, such as the head or chest, it can be
reasonably anticipated that death would occur. In this case, the defendant stabbed the
deceased in the chest, which is a vital part of the body. Therefore, the accused must be
presumed to have intended the natural consequences of their act, which is the death of the
victim.
The court also stated that provocation as a mitigating circumstance can only be considered if it
comes from the offended party. In this case, the deceased's refusal to return to the defendant
cannot be considered as provocation from the offended party. The court noted that it was the
defendant who initiated the attack by stabbing the deceased after she informed him of her
decision. Therefore, the court concluded that the defendant's claim of being attacked by the
deceased's relatives and the stabbing being accidental cannot be accepted.

Based on these reasons, the court affirmed the decision of the lower court, finding the
defendant guilty of homicide. The defendant was sentenced to imprisonment and ordered to
indemnify the heirs of the deceased.

• US vs. Marasigan, 27 Phil 504 (page 79)

- Marasigan drew his knife and struck Mendoza, Mendoza was cut in the left hand
because he attempted to defend himself. The extensor tendon in one of the fingers was
severed resulting that the middle finger of the left hand was useless
- Mendoza is not obliged to submit a surgical operation to relieve the accused from natural
and ordinary results of his crime. The voluntary act of Marasigan disabled Mendoza so
he must face the consequences of his action without Mendoza’s aid.

Facts: The accused drew his knife and struck at Mendoza. In attempting to ward off the
blow, Mendoza was cut in the left hand. The extensor tendon in one of the fingers was
severed. As a result, the middle finger of the left hand was rendered useless.

Held: Nor do we attach any importance to the contention of the accused that the original
condition of the finger could be restored by a surgical operation. Mendoza is not obliged
to submit to a 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 without aid from Mendoza.

• People vs. Moldes, GR No. 42122, Dec. 01, 1934

Facts:
In the case of People v. Moldes, the appellant, Inocentes Moldes, was convicted of homicide
after fatally injuring the deceased during a dance altercation. The incident took place on the
night of April 3, in the barrio of Maya, municipality of Abuyog, Province of Leyte. The appellant
insisted on dancing out of turn and was reprimanded by the deceased, who was the master of
ceremonies at the dance. The appellant then went to the porch of the house and began cutting
down the decorations with his bolo. He challenged everyone to a fight and started chopping at
the bamboo trees. The unarmed deceased approached the appellant in a friendly manner, but
the appellant struck him with his bolo, inflicting a serious wound on his left arm. The deceased
fell to the ground, and the appellant inflicted a slight wound in his back before fleeing the scene.
The deceased received treatment the next morning but died on April 15 due to the severity of
his injuries.
Issue:
The main issue in the case was whether the appellant acted in self-defense or was the
aggressor in the altercation.

Ruling:
The court ruled that there was no element of self-defense in the case and that the appellant was
responsible for the natural consequences of his actions.

Ratio:
The court based its ruling on the fact that when someone resorts to the use of a lethal weapon
and strikes another with force, it is presumed that they realize the potential harm they can
cause. In this case, the appellant struck the deceased with a bolo, a deadly weapon, inflicting
serious and fatal injuries. The court rejected the defense's argument that the appellant struck
the deceased in self-defense, as it did not find the defense witnesses credible. The court
concluded that the appellant was the aggressor in the altercation.

The court also addressed the argument raised by the defense regarding the deceased's death
potentially being prevented with proper surgical treatment. The court stated that the person who
inflicts a dangerous wound is responsible for the consequences, regardless of the quality of
medical treatment available. Therefore, the appellant was held responsible for the death of the
deceased.

The defense also raised an objection regarding the questions asked about the character and
habits of the deceased during the trial. However, the court did not find these questions relevant
to the issue at hand and did not address the objection.
In conclusion, the court affirmed the judgment of the Court of First Instance, convicting the
appellant of homicide. The appellant was sentenced to a period of confinement ranging from six
years and one day of prision mayor to fourteen years, eight months, and one day of reclusion
temporal.

• People vs. Joel Clemente, GR No. 231614, Jan. 22, 2020

- Clemente charged with murder in relation to RA 9262 under the provisions of Article 248
of the RPC for killing his live in partner AAA
- October 16, 2007; Malolos, Bulacan; Clemente with intent to kill,with evident
premeditation, treachery, abuse of superior strength, ignominy and cruelty,
attacked/assaulted, kicked AAA

The Case

This appeal 1 seeks to reverse and set aside the Decision 2 dated October 25, 2016 of
the Court of Appeals in CA-G.R. CR No. 07407 affirming the conviction against appellant
Joel Clemente y Hernandez for Murder. HTcADC
The Proceedings before the Regional Trial Court

The Charge

Appellant was charged with Murder in relation to Republic Act No. 9262 3 (RA No. 9262)
under the provisions of Article 248 of the Revised Penal Code (RPC), for killing his live-
in partner "AAA." The Amended Information 4 reads:

That on or about the 26th day of October, 2007, in the City of Malolos, province of
Bulacan, Philippines, and within the Jurisdiction of this Honorable Court, the above-
named accused, with intent to kill [AAA], with evident premeditation, Treachery, abuse of
superior strength, ignominy, and cruelty, did then and there willfully, unlawfully and
feloniously attack, assault, punch and kick said [AAA], live-in-partner of the accused,
hitting her on the different parts of her body and inflicting upon her serious physical
injuries which directly caused the death of the said [AAA].

Contrary to Law.

The case was raffled to the Regional Trial Court (RTC)-Branch 77, Malolos City,
Bulacan. On Arraignment, appellant pleaded not guilty. Trial thereafter ensued.

Version of the Prosecution

In the morning of October 26, 2007, AAA went to her parents' house to help her mother
sell cooked food. Around 10 o'clock in the morning, she went home to appellant's house
where they lived together with her son BBB. 5 AAA arrived there around noon time and
found appellant already drunk. 6

BBB, then playing outside the house, heard appellant and AAA arguing. Appellant was
mad and yelling at AAA for there was no food to eat. 7 BBB sneaked inside the house
and saw appellant mauling AAA. Appellant punched AAA three (3) times, hitting her in
the face, in the right temple. Appellant also kicked AAA and continued mauling her
despite her pleas. 8

AAA tried to escape but appellant chased her and grabbed her hair as she was heading
out of the house. Appellant continued mauling AAA outside their house even while BBB
and their neighbors were watching. Nobody managed to help AAA because appellant
threatened to kill anyone who would meddle in their fight. 9 When AAA fainted, appellant
stopped mauling her and carried her to the bathroom. Appellant bathed AAA. When AAA
regained consciousness, appellant brought her back to their room and made her sleep.
10

Around 6 o'clock in the evening, BBB noticed that AAA was having trouble breathing and
her hands were cold. BBB tried to wake her up and applied Katinko oil on her stomach.
He also woke up appellant. Appellant then brought AAA to the hospital, leaving BBB in
the house. 11

Around 7 o'clock in the evening, AAA's parents received a call from the hospital, telling
them to go to the morgue as their daughter was already dead. 12

The following day, Dr. Victor Antonino Batanes did a post mortem examination on AAA's
body and found that AAA sustained multiple physical injuries, several abrasions and
hematoma throughout her body, particularly in her head and face, which led to massive
intracranial hemorrhages or a bleeding of the brain that resulted in her death. He
explained that any external blunt force is sufficient to cause bleeding of the brain,
including a fist blow in the head. 13

Version of the Defense

Appellant testified that around 7 o'clock in the morning of October 26, 2007, he was on
his way to work when their neighbor Rosie told him that AAA was having an affair with
another man. AAA was allegedly giving her (Rosie's) daughter and BBB money so that
whenever they see appellant coming, they should warn AAA. This made him angry at
AAA. 14

Around 10 o'clock in the morning, he was already home, drinking liquor while waiting for
AAA. When AAA arrived, he confronted AAA but the latter denied the accusation. AAA
angrily went outside the house, picked up a piece of hollow block and threw it at him.
They started fighting and hitting each other. He slapped her, chased her, and told her to
go back inside the house to avoid scandal. AAA tripped, fell on the floor with her
headfirst, and, as a result, bruised her forehead. When he saw AAA's head bleeding, he
told BBB to get a cloth to wipe off the blood. AAA then ran away so he chased and
pulled her back into their house. But AAA bumped her face against her knees until he
calmed her down and brought her back inside their house. When they got inside their
house, they took a bath together and slept in their room together with BBB. 15

When he woke up around 6 o'clock in the evening, AAA was hugging him and still
sleeping. After cleaning the kitchen, he returned to their room and tried to wake up AAA.
At this point, BBB woke up and told him that he heard AAA groaning. Rosie and another
neighbor helped him bring AAA to the hospital, where AAA later died. He, together with
his mother and uncle, went to the police station to report the incident. 16

The Ruling of the Regional Trial Court (RTC)

In its Decision 17 dated February 18, 2015, the Regional Trial Court (RTC)-Branch 77,
Malolos City, Bulacan found appellant guilty of Physical Harm constituting Murder under
Section 5 (a) of RA No. 9262, viz.:
 (1) Sentenced to Reclusion Perpetua, without the right to parole; and

(2) Ordered to pay the heirs of the victim, [AAA], P75,000 in civil indemnity, P50,000
in moral damages, and P30,000 in exemplary damages. Each of the
aforementioned amounts shall accrue interest at a rate of 6% per year from the
finality of this decision until fully paid.

So Ordered.

The trial court noted there was no showing that BBB was impelled by ill will when he
positively testified against appellant as the person who slayed his mother.

The Proceedings before the Court of Appeals

On appeal, appellant faulted the trial court for convicting him despite the alleged
inconsistencies or contradictions in the prosecution's Evidence, particularly in BBB's
testimony.

The Office of the Solicitor General (OSG), on the other hand, riposted that the
prosecution had sufficiently established appellant's guilt of the offense of violence
against women and their children under Section 5 (a) of RA 9262 constituting Murder
under Article 248 of the Revised Penal Code (RPC). Appellant should also pay a fine as
RA 9262 imposes both imprisonment and fine for offenses involving violence against
women and their children.

The Ruling of the Court of Appeals

By Decision 20 dated October 25, 2016, the Court of Appeals affirmed. It sustained the
trial court's factual findings on the credibility of the Witnesses and its assessment of the
Evidence on record, including the existence of the qualifying circumstances of evident
premeditation and abuse of superior strength.

Pursuant to RA 9262, the Court of Appeals further imposed a fine of P100,000.00 and
ordered appellant to undergo psychological counseling and to report to the trial court his
compliance therewith.

The Present Appeal

Appellant now seeks affirmative relief from the Court and prays anew for a verdict of
Acquittal. In compliance with Resolution 21 dated July 17, 2017, both appellant and the
People manifested that, in lieu of supplemental briefs, they were adopting their
respective briefs filed before the Court of Appeals.
Issue

Did the Court of Appeals err in affirming the trial court's verdict of conviction?

Ruling

RA 9262 defines "violence against women and their children" as any act or a series of
acts committed by any person against a woman who is his wife, former wife, or against a
woman with whom the person has or had a sexual or dating relationship, or with whom
he has a common child, or against her child whether legitimate or illegitimate, within or
without the family abode, which results in or is likely to result in physical, sexual,
psychological harm or suffering, or economic abuse including threats of such acts,
battery, assault, coercion, harassment or arbitrary deprivation of liberty.

Section 5 (a) in relation to Section 6 (a) specifically provides that when the acts of
violence committed by causing physical harm to the woman constitute Murder, the same
shall be punished in accordance with the provisions of the Revised Penal Code, with the
additional penalty of fine and mandatory psychological counseling, viz.:

Section 5.Acts of Violence Against Women and Their Children. — The crime of violence
against women and their children is committed through any of the following acts:

(a)Causing physical harm to the woman or her child;

xxx xxx xxx.

Section 6.Penalties. — The crime of violence against women and their children, under
Section 5 hereof shall be punished according to the following rules:

(a)Acts falling under Section 5(a) constituting attempted, frustrated or consummated

Parricide or Murder or homicide shall be punished in accordance with the provisions of
the Revised Penal Code.

xxx xxx xxx

In addition to imprisonment, the perpetrator shall (a) pay a fine in the amount of not less
than One hundred thousand pesos (P100,000.00) but not more than three hundred
thousand pesos (P300,000.00); (b) undergo mandatory psychological counseling or
psychiatric treatment and shall report compliance to the court.

Here, the Evidence sufficiently established that appellant committed acts of violence
against AAA and these acts constitute Murder. Considering that appellant and AAA were
live in partners, the trial court correctly found appellant liable under RA 9262. The proper
 nomenclature of the crime, however, should be "violation of Section 5 (a) in relation to
Section 6 (a) of RA 9262, constituting Murder under Article 248 of the Revised Penal
Code."

The trial court gave greater weight to BBB's positive, clear, and categorical testimony
over appellant's denial. BBB was present when the mauling incident took place. He
vividly narrated how appellant viciously and repeatedly mauled AAA, resulting in the
latter's demise.

ACCORDINGLY, the appeal is DISMISSED. The Decision dated October 25, 2016 of
the Court of Appeals in CA-G.R. CR No. 07407 is AFFIRMED with MODIFICATION.
Appellant is found GUILTY of Violation of Section 5 (a) in relation to Section 6 (a) of RA
9262, constituting Murder under Article 248 of the Revised Penal Code and is sentenced
to Reclusion Perpetua without eligibility for parole.

B.3 Impossible Crimes [Art. 4, RPC]

Requisites for Impossible Crimes

1. The act performed would be an offense against persons or property.
2. The act was done with evil intent.
3. Its accomplishment is inherently impossible, or that the means employed is either
inadequate or ineffectual.
4. The act performed should not constitute violation of another provision of the R.P.C.

• People vs. Domasian, GR No. 95322, Mar. 1, 1993

Facts:

The case involves the People of the Philippines as the plaintiff-appellee and Pablito Domasian
and Dr. Samson Tan as the accused-appellants. The incident occurred on March 11, 1982, in
Lopez, Quezon. The victim, Enrico Paulo Agra, an 8-year-old boy, was approached by a man
later identified as Pablito Domasian, who requested his help in obtaining his father's signature
on a medical certificate. Enrico was then forcibly taken by Domasian, who restrained him and
dragged him into a minibus, then a tricycle, and finally to the market in Gumaca. The man
handed an envelope addressed to Enrico's father, Dr. Enrique Agra, to a jeepney driver named
Alexander Grate. Grate became suspicious and reported the matter to barangay tanods.
Domasian managed to escape, leaving Enrico behind. Enrico was later found by his parents. A
ransom note demanding P1 million for Enrico's release was received by Dr. Agra, who identified
the handwriting as that of Dr. Samson Tan, a resident physician in his hospital. Both Domasian
and Tan were charged with kidnapping with serious illegal detention. The trial court found them
guilty and sentenced them to reclusion perpetua, along with a fine of P200,000.00 for actual and
moral damages and attorney's fees. The accused appealed, denying their participation and
questioning the credibility of the prosecution witnesses.

Issue:
1. Whether the crime committed was kidnapping with serious illegal detention or merely
grave coercion.
2. Whether the positive identification of the accused by the prosecution witnesses is
credible.
3. Whether the ransom note was written by Dr. Samson Tan.
4. Whether there was a conspiracy between Domasian and Tan.
5. Whether the constitutional rights of the accused were violated during their arrest and
detention.

Ruling:
1. The Supreme Court upheld the conviction for kidnapping with serious illegal detention.
2. The Court found the positive identification of the accused by the prosecution witnesses
credible.
3. The Court affirmed that the ransom note was written by Dr. Samson Tan.
4. The Court found that there was a conspiracy between Domasian and Tan.
5. The Court ruled that the alleged constitutional violations did not affect the conviction.

Ratio:
1. The Court ruled that the crime of kidnapping with serious illegal detention was committed
as defined under Article 267 of the Revised Penal Code. The victim was deprived of his
liberty by Domasian, who restrained him and dragged him to various locations. The fact
that the victim was not confined in an enclosure did not negate the crime.
2. The credibility of the prosecution witnesses was upheld by the trial judge, who had the
opportunity to observe their demeanor. The victim, Enrico, and other witnesses positively
identified Domasian as the person who detained him. The Court found no reason to
doubt their testimonies.
3. The Court relied on the testimony of an NBI handwriting expert, who concluded that the
ransom note was written by Dr. Samson Tan. The trial court found the NBI expert's
examination more comprehensive than that of the PC/INP expert. Additionally, Dr. Agra,
familiar with Tan's handwriting, also identified the note as written by Tan.
4. The Court found that the acts of Domasian in detaining Enrico, the writing of the ransom
note by Tan, and its delivery to Dr. Agra indicated a conspiracy. These acts were
complementary and aimed at extorting ransom.
5. The Court held that the alleged constitutional violations, such as arrest without a warrant
and torture, did not vitiate the conviction as no confession was obtained. The seizure of
documents for handwriting comparison was done by Dr. Agra, a private individual, and
not by law enforcement, thus not violating the Bill of Rights.

• Intod vs. People, GR No. 103119, Oct. 21, 1992 (Intod vs. CA ?)
Facts:
The case involves petitioner Sulpicio Intod, who was convicted of attempted murder by the
Regional Trial Court (RTC) of Oroquieta City, a decision later affirmed by the Court of Appeals.
On February 4, 1979, Intod, along with Jorge Pangasian, Santos Tubio, and Avelino Daligdig,
went to Salvador Mandaya's house in Katugasan, Lopez Jaena, Misamis Occidental. They
coerced Mandaya to accompany them to Bernardina Palangpangan's house, as Aniceto
Dumalagan had ordered Palangpangan's killing due to a land dispute. At around 10:00 PM, the
group, armed with firearms, arrived at Palangpangan's house. Mandaya pointed out
Palangpangan's bedroom, and the group fired shots into the room. However, Palangpangan
was not present; her son-in-law and his family were occupying the house, and no one was hit.
Witnesses identified Intod and his companions, who threatened to return and kill Palangpangan.
The RTC convicted Intod of attempted murder, a decision upheld by the Court of Appeals. Intod
then petitioned for a review, arguing that he should be liable only for an impossible crime under
Article 4(2) of the Revised Penal Code, as the crime was inherently impossible due to
Palangpangan's absence.

Issue:
1. Was the crime committed by Sulpicio Intod and his companions an attempted murder or
an impossible crime under Article 4(2) of the Revised Penal Code?

Ruling:
The Supreme Court modified the decision of the Court of Appeals, holding Sulpicio Intod guilty
of an impossible crime under Article 4(2) of the Revised Penal Code. The Court sentenced him
to six months of arresto mayor, along with the accessory penalties provided by law, and to pay
the costs.

Ratio:
The Court's decision was based on the interpretation of Article 4(2) of the Revised Penal Code,
which penalizes acts that would constitute an offense against persons or property if not for the
inherent impossibility of their accomplishment. The Court distinguished between legal and
factual impossibility, explaining that legal impossibility occurs when the intended acts, even if
completed, would not amount to a crime, while factual impossibility occurs when extraneous
circumstances prevent the consummation of the intended crime. In this case, the crime was
factually impossible because Palangpangan was not present in the room when the shots were
fired. The Court emphasized that the Revised Penal Code recognizes impossible crimes, unlike
American law, which treats impossibility as a defense to an attempt charge. The Court
concluded that the physical impossibility of accomplishing the intended crime rendered it an
impossible crime under Article 4(2), and thus, Intod should be held liable for an impossible crime
rather than attempted murder.

• People vs. Enoja, GR No. 102596, Dec. 17, 1999

Facts:
The case "People vs. Enoja" involves five farmers from Barangay Caraudan, Janiuay, Iloilo,
namely Nicasio Enoja @ "Nick", Jose Enoja @ "Moros", Antonio Galupar @ "Tony", Ronnie
Enoja @ "Bud-oy", and Yolly Armada. They were convicted of murder for killing Siegfred G.
Insular, a suspected commander of the "New People's Army" (NPA). The incident occurred on
July 2, 1987, when Siegfred and his wife, Paterna, were walking home from the market. They
encountered Yolly Armada, who shot Siegfred multiple times. Subsequently, the other accused
appeared and also fired at Siegfred, resulting in his death. The trial court found the accused
guilty of murder, citing conspiracy and treachery, and sentenced them accordingly. The case
was appealed, and the Supreme Court reviewed the decision. The trial court's decision was
based on testimonies from eyewitnesses, including Paterna Insular and Teodoro Salamanca,
and the medico-legal officer who conducted the autopsy. The defense presented alibis and
claimed self-defense, but these were not accepted by the court. The trial court's decision was
rendered on October 31, 1990, and the appeal was decided by the Supreme Court on
December 17, 1999.

Issue:
1. Did the trial court err in finding conspiracy among the accused?
2. Did the trial court err in finding the accused-appellants guilty of murder?
3. Should the offense committed be considered an impossible crime rather than murder?

Ruling:
1. The Supreme Court affirmed the trial court's finding of conspiracy.
2. The Supreme Court upheld the trial court's decision finding the accused-appellants guilty
of murder.
3. The Supreme Court rejected the defense's argument that the offense committed was an
impossible crime.

Ratio:
1. Conspiracy: The Supreme Court held that conspiracy need not be shown by direct proof
of an agreement but can be inferred from the conduct of the accused before, during, and
after the commission of the crime. The simultaneous and successive shooting by the
accused, the planting of a firearm near the victim, and the shooting of Antonio to
fabricate a self-defense scenario all indicated a concerted effort to kill Siegfred. The
testimonies of Paterna and Salamanca were consistent and credible, establishing the
presence of conspiracy.
2. Guilt of Murder: The Court found that the evidence presented, including the eyewitness
accounts and the autopsy report, clearly established the guilt of the accused. The
presence of treachery was evident as the attack was sudden and unexpected, leaving
the victim no chance to defend himself. The defense of alibi and self-defense was not
credible, especially given the positive identification of the accused by the witnesses and
the inconsistencies in the defense's testimonies.
3. Impossible Crime: The Court dismissed the argument that the offense was an impossible
crime. The defense's theory that the victim was already dead when the subsequent
shots were fired was speculative and contradicted their alibi. The Court emphasized that
 the defense of impossible crime is incompatible with the defense of alibi and denial. The
evidence showed that the victim was still alive when the accused took turns shooting
him, thus constituting murder.
The Supreme Court modified the trial court's decision by increasing the indemnity to P50,000.00
and deleting the award of actual damages due to lack of receipts. The penalties imposed on the
accused were affirmed, with Nicasio Enoja sentenced to reclusion perpetua and Ronnie Enoja
given an indeterminate sentence due to his minority at the time of the crime.

B.4 Doctrine of Proximate Cause

Proximate Cause (Legal Cause)

- primary cause or an incident that set everything in motion
(ex. if a car runs a red light at the intersection while you were passing and it strikes/hits
you, the car’s movement is the actual cause or cause in fact of the pedestrian crash

• Vda. De Bataclan vs. Medina, 102 Phil 181

(GR No. L-10126)

Facts:
On September 13, 1952, shortly after midnight, bus No. 30 of Medina Transportation, operated
by defendant Mariano Medina, left Amadeo, Cavite en route to Pasay City. The bus, driven by
Conrado Saylon, had about eighteen passengers, including Juan Bataclan, who was seated
beside the driver. At around 2:00 AM, within the jurisdiction of Imus, Cavite, a front tire burst,
causing the bus to zigzag and eventually overturn into a ditch. Some passengers managed to
escape, but Bataclan and three others were trapped inside. Despite calls for help, it took about
half an hour for rescuers to arrive, one of whom carried a lighted torch. The torch ignited leaking
gasoline, resulting in a fire that consumed the bus and killed the trapped passengers. Salud
Villanueva, Bataclan's widow, along with her five minor children, filed a suit against Medina for
compensatory, moral, and exemplary damages, totaling P87,150. The Court of First Instance of
Cavite awarded P1,000 plus attorney's fees and the value of lost merchandise. Both parties
appealed to the Court of Appeals, which forwarded the case to the Supreme Court due to the
amount involved.

Issue:
1. Was the proximate cause of Bataclan's death the overturning of the bus or the
subsequent fire?
2. Is the defendant liable for the negligence of his driver and conductor in failing to prevent
the fire?

Ruling:
1. The Supreme Court held that the proximate cause of Bataclan's death was the
overturning of the bus.
2. The Court found the defendant liable for the negligence of his driver and conductor.
Ratio:
The Supreme Court explained that proximate cause is defined as the cause that, in a natural
and continuous sequence, produces the injury and without which the result would not have
occurred. In this case, the overturning of the bus set off a chain of events that led to the fire. The
leaking gasoline was a foreseeable consequence of the bus overturning, and the arrival of
rescuers with a torch was a natural response to the calls for help. The Court noted that the
driver and conductor were negligent in not warning the rescuers about the gasoline leak, which
could have prevented the fire. The Court referenced Articles 1733, 1759, and 1763 of the Civil
Code, which impose a duty of extraordinary diligence on common carriers for the safety of their
passengers. The Court increased the damages awarded to P6,000 for compensatory, moral,
and other damages, and P800 for attorney's fees, affirming the trial court's decision with
modifications. Additionally, the Court expressed concern over the provisional dismissal of the
criminal case against the driver and urged the Department of Justice and the Provincial Fiscal of
Cavite to pursue the prosecution to promote public safety.

• Urbano vs. People, GR No. 182750, Jan. 20, 2009

Facts:
In the case of "Urbano v. People," petitioner Rodel Urbano was charged with Homicide for the
death of Brigido Tomelden. The incident occurred on the evening of September 28, 1993, in
Barangay Poblacion, Lingayen, Pangasinan. Urbano and Tomelden, along with other co-
workers, had been drinking beer at a restaurant in Bugallon, Pangasinan. Upon returning to the
Lingayen Water District (LIWAD) compound, a heated altercation ensued between Urbano and
Tomelden, during which Tomelden hurled insults at Urbano. The altercation escalated into a
fistfight, and Urbano delivered a punch to Tomelden's face, causing him to bleed from the nose
and lose consciousness. Tomelden was taken to the office of the LIWAD general manager and
later to the hospital, where he was treated for various injuries. Despite medical attention,
Tomelden's condition worsened, and he died on October 10, 1993, due to cardio-respiratory
arrest secondary to cerebral concussion with resultant cerebral hemorrhage. Urbano was found
guilty of Homicide by the Regional Trial Court (RTC) of Lingayen, Pangasinan, and sentenced
to an indeterminate prison term of eight years and one day of prision mayor as minimum to
seventeen years and four months of reclusion temporal as maximum. The Court of Appeals
(CA) affirmed the conviction but modified the decision to include an award of PHP50,000.00 in
moral damages to the heirs of Tomelden. Urbano then filed a petition for review under Rule 45
to the Supreme Court.

Issue:
1. Did the Court of Appeals err in affirming the RTC's decision finding Urbano guilty beyond
reasonable doubt of Homicide?
2. Should the mitigating circumstances of sufficient provocation on the part of the victim
and lack of intent to commit so grave a wrong be appreciated in favor of Urbano?

Ruling:
 1. The Supreme Court affirmed the conviction of Urbano for Homicide.
2. The Supreme Court found that the mitigating circumstances of sufficient provocation on
the part of the victim and lack of intent to commit so grave a wrong should be
appreciated in favor of Urbano. Consequently, the Court modified the sentence to an
indeterminate prison term of two years and four months of prision correccional as
minimum to eight years and one day of prision mayor as maximum.

Ratio:
The Supreme Court held that the evidence presented by the prosecution, including eyewitness
testimonies and medical reports, established beyond reasonable doubt that Urbano's punch
was the proximate cause of Tomelden's death. The Court noted that the punch caused
Tomelden to lose consciousness and suffer from severe head pain, which eventually led to his
death due to cerebral concussion and hemorrhage. The Court also found that the mitigating
circumstances of sufficient provocation and lack of intent to commit so grave a wrong were
present. Tomelden's insulting remarks and aggressive behavior provoked Urbano, and Urbano's
actions were in response to the provocation. Additionally, Urbano did not intend to kill
Tomelden, as evidenced by his attempts to avoid the fight and his actions after the incident. The
Court applied Article 64, paragraph 5 of the Revised Penal Code, which allows for the
imposition of the next lower penalty when two or more mitigating circumstances are present
without any aggravating circumstances. Therefore, the Court modified Urbano's sentence to an
indeterminate prison term of two years and four months of prision correccional as minimum to
eight years and one day of prision mayor as maximum. The award of civil indemnity and moral
damages was affirmed.

• Seguritan vs. People, GR No. 172896, Apr. 19, 2010

Facts:
The case of "Seguritan y Jara v. People" involves the petitioner, Roño Seguritan y Jara, who
was charged with homicide for the death of his uncle, Lucrecio Seguritan. The incident occurred
on November 25, 1995, in Barangay Paradise, Gonzaga, Cagayan, during a drinking session.
An argument ensued between Roño and Lucrecio over a carabao that allegedly destroyed
Roño's crops. Roño punched Lucrecio twice, causing him to fall and hit his head on a hollow
block, leading to his death later that night. The Regional Trial Court (RTC) of Aparri, Cagayan,
Branch 06, found Roño guilty of homicide and sentenced him to an indeterminate sentence of 6
years and 1 day of prision mayor as minimum to 17 years and 4 months of reclusion temporal
as maximum. The Court of Appeals (CA) affirmed the conviction with modifications, reducing the
maximum sentence to 12 years and 1 day of reclusion temporal. Roño's motion for
reconsideration was denied, leading to this petition for review on certiorari.

Issue:
1. Did the Court of Appeals err in affirming the trial court's judgment of conviction?
2. Did the Court of Appeals err in convicting the accused of the crime of homicide?

Ruling:
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals, which
found Roño Seguritan y Jara guilty of homicide. The Court upheld the indeterminate penalty of
six years and one day of prision mayor as minimum, to 12 years and one day of reclusion
temporal as maximum. Additionally, the Court ordered Roño to pay the heirs of Lucrecio
Seguritan P50,000.00 as moral damages, P135,331.00 as loss of earning capacity, P25,000.00
as temperate damages in lieu of actual damages, and P50,000.00 as civil indemnity.

Ratio:
The Supreme Court found no reason to doubt the findings of the trial court, as affirmed by the
appellate court, that Roño's punches caused Lucrecio to fall and sustain fatal head injuries. The
Court emphasized that the factual findings of the trial court are generally accorded great weight
and respect on appeal, especially when supported by substantial evidence. The autopsy report
and the testimony of Dr. Antonio Vertido confirmed that Lucrecio died of traumatic head injury,
ruling out the defense's claim of a heart attack. The Court also noted that the defense failed to
provide evidence that the delay in the autopsy or the embalming compromised the results. The
Court reiterated that under Article 4 of the Revised Penal Code, a person committing a felony is
criminally liable even if the wrongful act done is different from that which was intended. Roño's
act of punching Lucrecio, even without intent to kill, made him liable for homicide as the cause
of the cause is the cause of the evil caused. The Court also addressed the issue of damages,
awarding temperate damages in lieu of actual damages due to the lack of receipts and
supporting documents for the claimed expenses.

• People vs. Marco, GR Nos. L-28324-5, May 19, 1978

Facts:
The case of People v. Marco involves an altercation in Barrio Subang, Zamboanga del Sur,
where Rafael Marco, along with his son Simeon Marco and Dulcisimo Beltran, faced criminal
liability for assaulting multiple individuals. The incident occurred on November 5, 1964, during a
fiesta in the market place of Barrio Subang. The events unfolded when Simeon approached
Constancio Sabelbero and inquired if he was the one who had assaulted his brother the
previous year. Simeon then brandished a hunting knife, causing Constancio to flee. As
Constancio was running, he crossed paths with Rafael, who struck him with a cane, resulting in
slight physical injuries. Vicente, Constancio's father, intervened and grabbed Simeon's hand
holding the knife upon seeing Rafael approaching. Vicente shouted for Constancio and his other
son, Bienvenido, to escape, which they did. Rafael pursued Bienvenido and attempted to stab
him, but Bienvenido managed to deflect the blow, causing injuries to his left hand. Bienvenido
tried to flee further but tripped and fell due to entangled vines. Suddenly, Beltran emerged and
stabbed Bienvenido near the anus, followed by Simeon, who stabbed him on the left side of the
breast. Tragically, Bienvenido succumbed to his injuries. The trial court found Rafael, Simeon,
and Beltran guilty of murder based on the theory of obvious conspiracy. Only Rafael appealed
the decision.

Issue:
The main issue in this case is whether Rafael Marco can be held liable for the murder of
Bienvenido Sabelbero, along with his co-accused Simeon Marco and Dulcisimo Beltran.

Ruling:
The Supreme Court ruled that Rafael Marco cannot be held liable for the murder of Bienvenido
Sabelbero. The court found that there was no conclusive proof of conspiracy among the
accused. The fact that their acts followed one after the other does not prove criminal conspiracy.
The court emphasized that conspiracy requires conclusive proof to maintain the principle of
proof beyond reasonable doubt. In this case, where the assaults were not simultaneous but
successive, greater proof is demanded to establish concert of criminal design. The court also
noted that there was no clear evidence connecting Rafael's act of trying to stab Bienvenido,
which caused injuries to his left hand, with the fatal stabs inflicted by his co-accused. The court
concluded that Rafael's act of stabbing Bienvenido is separate from the fatal stabs inflicted by
Simeon and Beltran. Therefore, Rafael can only be held liable for the slight physical injuries
caused by his act of stabbing Bienvenido's left hand. The court modified the decision and
sentenced Rafael to twenty days of arresto menor for slight physical injuries.

• People vs. Villacorta, GR No. 186412, Sep. 7, 2011

Facts:
The case involves the People of the Philippines as the plaintiff-appellee and Orlito Villacorta as
the accused-appellant. On June 21, 2002, an Information was filed against Villacorta, charging
him with the crime of murder for stabbing Danilo Salvador Cruz on January 23, 2002, in
Navotas, Metro Manila. The stabbing occurred at around 2:00 AM while Cruz was ordering
bread at Cristina Mendeja's sari-sari store. Villacorta, armed with a sharpened bamboo stick,
stabbed Cruz on the left side of his body without uttering a word and then fled the scene. Cruz
was treated as an out-patient at Tondo Medical Center and later admitted to San Lazaro
Hospital on February 14, 2002, where he died the following day due to tetanus infection
secondary to the stab wound. Villacorta denied the stabbing, claiming he only boxed Cruz after
Cruz put his arm around his shoulder. The Regional Trial Court (RTC) of Malabon found
Villacorta guilty of murder, qualified by treachery, and sentenced him to reclusion perpetua. The
Court of Appeals affirmed the RTC's decision. Villacorta appealed to the Supreme Court,
arguing that the prosecution failed to prove his guilt beyond reasonable doubt, that treachery
was improperly appreciated, and that he should only be liable for slight physical injuries.

Issue:
1. Did the prosecution prove Villacorta's guilt beyond reasonable doubt?
2. Was the qualifying circumstance of treachery properly appreciated?
3. Should Villacorta be held liable only for slight physical injuries?

Ruling:
1. The Supreme Court found that the prosecution proved Villacorta's guilt beyond
reasonable doubt.
2. The Court upheld the finding of treachery as an aggravating circumstance.
 3. The Court ruled that Villacorta should only be held liable for slight physical injuries due to
the lack of intent to kill and the proximate cause of death being tetanus infection.

Ratio:
The Supreme Court affirmed the credibility of the prosecution's eyewitness, Cristina Mendeja,
who positively identified Villacorta as the assailant. The Court noted that the trial court's
determination of witness credibility is given full weight and respect. Despite Villacorta's
arguments about inconsistencies in Mendeja's testimony, the Court found these to be
inconsequential to the fundamental fact that Villacorta stabbed Cruz. Villacorta's denial was
deemed weak and uncorroborated. However, the Court found merit in Villacorta's argument
regarding the proximate cause of Cruz's death. The Court cited the case of Urbano v.
Intermediate Appellate Court, which dealt with a similar situation where the victim died of
tetanus infection weeks after being injured. The Court concluded that the stab wound was the
remote cause, and the tetanus infection was the proximate cause of death. Therefore, Villacorta
was found guilty of slight physical injuries under Article 266 (1) of the Revised Penal Code. The
Court also appreciated treachery as an aggravating circumstance, as the attack was sudden
and left Cruz with no opportunity for self-defense. Villacorta was sentenced to thirty days of
arresto menor and ordered to pay P5,000.00 in moral damages to Cruz's heirs. Given that
Villacorta had been incarcerated since July 31, 2002, the Court ordered his immediate release.

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