People vs.

Luciano Barroga y Salgado

G.R. No. 31563 (1930)

FACTS:
Luciano prepared falsified documents with full knowledge of their falsity.
Such documents were but according to data furnished by his immediate chief.
Such acts were also in obedience to instructions to him.

ISSUE:
Whether or not Luciano is exempt from criminal liability for obedience of a
superior?

RULING:
No. In order to exempt from guilt, obedience must be in compliance with a
lawful order not opposed to a higher positive duty of a subaltern, and that the
person commanding, act within the scope of his authority.
People vs. Beronilla
G.R. No. L-4445 (1955)

FACTS:
In 1944, Beronilla is a Military Mayor, and was authorized by Lt. Col.
Arnold to appoint a jury of 12 bolomen to try persons accused of treason,
espionage, or the aiding and abetting of the enemy. In addition, he received a list
of puppet government officials of Abra, including Arsenio Borjal, and was
instructed to investigate said persons and gather complaints against them.
Aresnio Borjal is the Mayor of La Paz Abra. Beronilla placed Borjal under
custody and asked the residents to file charges against him. The trial before the
12-man jury end up convicting Borjal. That same day, Beronilla ordered the
execution of Borjal.
Jacinto was the executioner and Antonio was the grave digger. Beronilla
reported this report to Col. Arnold.

ISSUE:
Whether or not Luciano is exempt from criminal liability for obedience of a
superior?

RULING:
Yes. Beronilla acted upon orders of a superior officer that he could not
question. Moreover, he obeyed in good faith. A crime is not committed if the
mind of the person performing the act complained of be innocent.
Salvador Nassif vs. El Pueblo De Filipinas
G.R. No. 47509 (1941)

FACTS:

ISSUE:

RULING:

U.S. vs. Guevarra

G.R. No. 9265 (1914)

FACTS:
While Ignacia was starching clothes, Jose Guevarra slashed her with a bolo
several times. She died after more than one month because of the wounds.
Counsel for defense tried to prove that defendant was suffering from
insanity when he committed the act. However, Miguela, mother of deceased,
testified that Jose was sane for before the incident, he had spoken to her nicely.
President of board of health Pilares was asked to examine Jose to know if
he is insane. Althoungh he was seen swimming to his own urine while naked, and
always shouting The big man, Pilares still found him to be sane and normal.

ISSUE:
Whether or not Jose is insane?

RULING:
No. Per testimony of the expert witness, he is not insane when he
committed the crime. Thus, he is not exempt from criminal liability.
U.S. vs. Vaquilar
G.R. Nos. 9471 & 9475 (1914)

FACTS:
Evaristo Vaquilar was charged of parricide for killing his wife and
daughter. The morning before the incident, Evaristo felt pains in his head and
stomach, his eyes were very big, red, and his sight is penetrating. Several
witnesses testified that he seemed to be crazy. He often said the words: What
kind of people are you to me; what are you doing to me; you are beast!

ISSUE:
Whether or not Evaristo is insane?

RULING:
No. Crazy is not synonymous to insane, unsound mind, lunatic, or idiot.
Crazy as contemplated in the testimonies is that of having an unnatural trait i.e.
out of the ordinary. Insanity is not a presumption, and should be proven beyond
reasonable doubt.
People vs. Donato Bascos
G.R. No. L-19605 (1922)

FACTS:
Donato Bascos killed Victoriano Romero while the latter is sleeping. The
wife of the accused and his cousin testified that Donato had been continuously
out of his mind for years. Dr. Gonzalo Montemayor found the accused to be a
violent maniac.

ISSUE:
Whether or not Donato is insane?

RULING:
Yes. The testimony of the wife and his cousin was corroborated by an
expert witness. Insanity in this case was proven beyond reasonable doubt.
People vs. Crispino Mancao and Ciriaco Aguilar
G.R. No. 26361 (1927)

FACTS:
Roberto Villela refused to surrender the lands belonging to the intestate
estate of the deceased Hilaria Dejan, which were in his possession. While
Crispino is harvesting corns from said lands, he was confronted by Roberto
unarmed, but the former carried a stick and a bolo. Crispin assaulted Berto.
Roberto took a bolo and attempted to strike Crispino. When Crispino got
wounded, he grabed the bolo from Roberto and attacked the latter. The two fell
down, and Berto pinned Crispin. Ciriaco Aguilar told Roberto What have you
done to him? Ciriaco tried to hit Roberto with a bolo, but he hit Crispin. Ciriaco
is an epileptic, and as alleged in the defense, he is deprived of his reason.

ISSUE:
Whether or not Ciriaco should be exempt from criminal liability?

RULING:
No. Even if Ciriaco is an epileptic, therefore susceptible to nervous attacks
that may momentarily deprive him of his mental facilities and lead him to
unconsciously attempt to take his own life and lives of others, it has not been
shown that he was under the influence of an epileptic fit before, during, and
immediately after the aggression.
People vs. Juan N. Jimena
G.R. No. 33877 (1931)

FACTS:
Juan Gimena suspected Crispina, his wife of having illicit relations with
Apolinar Sereno (Apo) because she gave Apo P2.70. Juan attacked Crispina with
a bolo, but was stopped by Gregorio. Crispina died.
In defense, Juan claimed that he was in a state of somnambulism.

ISSUE:
Whether or not Juan should be exempt from criminal liability?

RULING:
No. Dr. Gomez did not find Juan to be in a state of somnambulism.
Moreover, granting that he was so suffering from such, somnambulism does not
constitute a defense other than that embraced in a plea of insanity.

[Somnambulism is an abnormal condition of sleep in which motor acts (as

walking) are performed.]
People vs. Valentin Doquea
G.R. No. 46539 (1939)

FACTS:
Juan Ragojos and Epifanio Rarag (Epi) were playing volleyball in their
school. Valentin (Val), a 7th grade pupil, joined them, but he hit Juan with the
ball in the stomach. Juan chased, slapped, and punched Val on the face. Juan
returned to Epi and played, and Val took a knife. Val stabbed Juan to death.
Val is one of the brightest in school and always obtained excellent remarks.
Thus, the trial court is convinced that Val committed the act with discernment.

ISSUE:
Whether or not Val committed the act with discernment?

RULING:
Yes. Discernment pertains to mental capacity to understand the difference
between right and wrong. Such capacity should be determined by taking into
consideration all the facts, circumstances, appearance, attitude, comportment
and behavior of the minor.