People vs Pugay

FACTS OF THE CASE:

The accused are pronounced by the RTC of Cavite guilty beyond reasonable doubt for the crime of
murder of Bayani Miranda and sentencing them to a prison term ranging from 12 years (prison
mayor) as mimimum to 20 years (prison temporal) as maximum and for samson to be sentenced to
reclusion perpetua.

Miranda and the accused Pugay are friends. Miranda used to run errands for Pugay and they used to
sleep together. On the evening of May 19, 1982 a town fiesta was held in the public plaza of Rosario
Cavite. Sometime after midnight accused Pugay and Samson with several companions arrived (they
were drunk), and they started making fun of Bayani Miranda. Pugay after making fun of the Bayani,
took a can of gasoline and poured its contents on the latter, Gabion (principal witness) told Pugay not
to do the deed. Then Samson set Miranda on fire making a human torch out of him. They were
arrested the same night and barely a few hours after the incident gave their written statements.

ISSUES OF THE CASE:

Is conspiracy present in this case to ensure that murder can be the crime? If not what are the criminal
responsibilities of the accused?

There is no:
CONSPIRACY- is determined when two or more persons agree to commit a felony and decide to
commit it. Conspiracy must be proven with the same quantum of evidence as the felony itself, more
specifically by proof beyond reasonable doubt. It is not essential that there be proof as to the
existence of a previous agreement to commit a crime. It is sufficient if, at the time of commission of
the crime, the accused had the same purpose and were united in its executed.
Since there was no animosity between miranda and the accused, and add to the that that the meeting
at the scene of the incident was purely coincidental, and the main intent of the accused is to make
fun of miranda.
Since there is no conspiracy that was proven, the respective criminal responsibility of Pugay and
Samson arising from different acts directed against miranda is individual NOT collective and each of
them is liable only for the act that was committed by him.

**Conspiracy may be implied from concerted action of the assailants in confronting the victim.

Criminal Responsibilities:
PUGAY: Having failed to exercise diligence necessary to avoid every undesirable consequence arising
from any act committed by his companions who at the same time were making fun of the deceased. -
GUILTY OF RECKLESS IMPRUDENCE RESULTING TO HOMICIDE

SAMSON:Since there are NO sufficient evidence that appears in the record establishing qualifying
circumstances (treachery, conspiracy). And granted the mitigating circumstance that he never
INTENDED to commit so grave a wrong. - GUILTY OF HOMICIDE

HELD:
JUDGEMENT OF THE LOWER COURT WAS AFFIRMED WITH MODIFICATIONS. JUDGEMENT FOR GUILTY
BEYOND REASONABLE DOUBT FOR MURDER WAS LOWERED TO THE ABOVE JUDGEMENTS.
US vs Ah Chong

FACTS:

August 14, 1908 About 10 pm: Ah Chong, a cook was suddenly awakened by some trying to
force open the door of the room. He sat up in bed and called out twice, "Who is there?" He heard
no answer and was convinced by the noise at the door that it was being pushed open by someone
bent upon forcing his way into the room. The defendant, fearing that the intruder was a robber or
a thief, leaped to his feet and called out. "If you enter the room, I will kill you." At that moment he
was struck just above the knee by the edge of the chair (thought to be an unlawful aggression)
which had been placed against the door. Seizing a common kitchen knife which he kept under his
pillow, the defendant struck out wildly at the intruder who, it afterwards turned out, was his
roommate, Pascual who is a house boy or muchacho who in the spirit of mischief was playing a
trick on him
Seeing that Pascual was wounded, he called to his employers and ran back to his room to
secure bandages to bind up Pascual's wounds.
There had been several robberies not long prior to the date of the incident, one of which took
place in a house where he was employed as cook so he kept a knife under his pillow for his
personal protection.
trial court held it as simple homicide

ISSUE: W/N defendant can be held criminally responsible who, by reason of a mistake as to the
facts, does an act for which he would be exempt from criminal liability if the facts were as he
supposed them to be, but which would constitute the crime of homicide or assassination if the
actor had known the true state of the facts at the time when he committed the act.

HELD: trial court should be reversed, and the defendant acquitted of the crime
NO.
GR: acts constituting the crime or offense must be committed with malice or with criminal intent
in order that the actor may be held criminally liable
EX: it appears that he is exempted from liability under one or other of the express provisions of
article 8 of the code
Article 1 RPC of the Penal Code is as follows:
Crimes or misdemeanors are voluntary acts and ommissions punished by law.
o A person voluntarily committing a crime or misdemeanor shall incur criminal liability, even
though the wrongful act committed be different from that which he had intended to commit.
o voluntary act is a free, intelligent, and intentional act
o "malice" signifying the intent
o Actus non facit reum nisi mens sit rea - "the act itself does not make man guilty unless his
intention were so
o Actus me incito factus non est meus actus - an act done by me against my will is not my act
GR: courts have recognized the power of the legislature to forbid, in a limited class of cases,
the doing of certain acts, and to make their commission criminal WITHOUT regard to the intent of
the doer
EX: intention of the lawmaker to make the commission of certain acts criminal without regard to
the intent of the doer is clear and beyond question the statute will not be so construed
ignorantia facti excusat applies only when the mistake is committed without fault or
carelessness
defendant at the time, he acted in good faith, without malice, or criminal intent, in the belief that
he was doing no more than exercising his legitimate right of self-defense; that had the facts been
as he believed them to be he would have been wholly exempt from criminal liability on account of
his act; and that he can not be said to have been guilty of negligence or recklessness or even
 carelessness in falling into his mistake as to the facts, or in the means adopted by him to defend
himself from the imminent danger which he believe threatened his person and his property and
the property under his charge.

People vs Oanis

FACTS:

Antonio Oanis and Alberto Galanta were instructed to arrest a notorious criminal and escaped convict,
Anselmo Balagtas, and if overpowered, to get him dead or alive. They went to the suspected house then
proceeded to the room where they saw the supposedly Balagtas sleeping with his back towards the
door. Oanis and Galanta simultaneously or successively fired at him which resulted to the victims
death. The supposedly Balagtas turned out to be Serepio Tecson, an innocent man.

ISSUE:

1. WON Oanis and Galanta incur no liability due to innocent mistake of fact in the honest performance
of their official duties.

2. WON Oanis and Galanta incur no criminal liability in the performance of their duty.

HELD:

1. No. Innocent mistake of fact does not apply to the case at bar. Ignorance facti excusat applies only
when the mistake is committed without fault or carelessness. The fact that the supposedly suspect was
sleeping, Oanis and Galanta could have checked whether it is the real Balagtas.

2. No. Oanis and Galanta are criminally liable. A person incurs no criminal liability when he acts in the
fulfillment of a duty or in the lawful exercise of a right or office. There are 2 requisites to justify this: (1)
the offender acted in teh perfomance of a duty or in the lawful exercise of a right or office, (2) that the
injury or offense committed be the necessary consequence of the due performance of such duty or the
lawful exercise of such right or office. In this case, only the first requisite is present.

People vs Guillen
People v. Guillen GR No. L-1477, January 18, 1950
FACTS:
 The accused Julio Guillen, was found guilty beyond reasonable doubt of the crime of murder and
multiple frustrated murder after his attempt to assassinate the President of the Philippines, Manuel
Roxas on March 10, 1947.During the 1946 Presidential Elections, Guillen voted for the opposing
candidate of Manuel Roxas. According to the accused, he was disappointed with the latter for failing
to redeem and fulfill promises made by President Roxas during the elections. Consequently, the
accused determined to assassinate the President and found the opportunity to do so on the night of
March 10, 1947 when the President attended a popular meeting by the Liberal Party at Plaza de
Miranda, Quiapo, Manila. Guillen first intended to use a revolver to accomplish his goal but he had
previously lost his licensed firearm, so he thought of using two hand grenades which were given to
him by an American soldier in exchange for two bottles of whisky. The accused stood on the chair
he had been sitting on and hurled the grenade at the President when the latter 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 was likely to do the least harm. The
grenade exploded in the middle of a group of persons standing close to the platform and grenade
fragments seriously injured Simeon Varela, who died the next day due to the mortal wounds
caused, and several other persons. Guillen was arrested and he readily admitted his responsibility.

ISSUE:WON the accused was guilty only of homicide through reckless imprudence in regard to the
death of Simeon Varela and of less serious physical injuries in regard to the other injured persons.

HELD:
The facts do not support the contention of the counsel for the appellant. In throwing the hand
grenade 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. As provided by Art. 4 of the Revised
Penal Code, criminal liability is incurred by any person committing a felony although the wrongful act
done be different from that which he intended. In criminal negligence, the injury caused to another
should be unintentional, it being simply the incident of another act performed without malice. As held
by thie Court, a deliberate intent to do an unlawful act is essentially inconsistent with the idea of
reckless imprudence. Where such unlawful act is wilfully done, a mistake in the identity of the
intended victim cannot be considered reckless imprudence
People vs Umawid
Facts:
On November 26, 2002 at around 4 o'clock in the afternoon, Vicente Ringor was staying with
his two-year old granddaughter, Maureen Joy Ringor, at the terrace of their house located at
Villanueva, San Manuel, Isabela. Suddenly, Roger Ringor Umawid appeared and started
attacking Vicente with a long bolo (panabas) without any reason. While Vicente was able to
escape Umawid's blows, the latter nevertheless hit Maureen on her abdomen and back,
causing her instant death. Upon seeing Maureen bloodied, Umawid walked away.

Thereafter, Umawid went to a nearby house which was only five meters away from Vicente's
house where his nephew, Jeffrey Mercado, was sleeping. Awaken by the sudden noise,
Jeffrey went outside only to see his uncle rushing to attack him with his panabas.

Jeffrey, along with his sister and cousin, rushed inside the house to seek for safety. However,
Umawid was able to prevent Jeffrey from closing the door and the former barge into the
house. Jeffrey crouched and covered his head with his arms to shield him from Umawid's
impending attacks.

Umawid delivered fatal hacking blows to Jeffrey, causing the mutilation of the latter's fingers.
Umawid only stopped upon seeing Jeffrey, who was then pretending to be dead, leaning on
the wall and blood-stained.

In court, Umawid set up the defense of insanity, but did not, however, take the witness stand
to attest the same. Instead, he presented the testimonies of Dr. Arthur M. Quincina and Dr.
Leonor Andres Juliana to support his claim. Dr. Quincina testifies that he evaluated Umawid's
psychiatric condition in May 2002, February 2003, and on March 2003 and found that the
latter was evident od psychotic symptoms. However, he could not tell with certainty whether
Umawid was psychotic at the time of the commission of the crimes. On the other hand, Dr.
Juliana failed to testify on Umawid's mental stare since she merely referred the latter to
another doctor for further evaluation.

Issue:
Whether or not the accused is exempted from criminal liablity due to insanity?

Ruling:
No. Under Article 12 of the RPC:

Article 12. Circumstances which exempt from criminal liabity - The following are exempt from
criminal liability:
1. An imbecile or an insane person, unless the latter has acted during a lucid interval.

The defense of insanity is in the nature of confession and avoidance because an accused
invoking the same admits to have committed the crime but claims that he or she is not guilty
because of insanity. The presumption is in favor of sanity, anyone who pleads the said
defense bears the burden of proving it with clear and convincing evidence. Considering the
case, the evidence must relate to the time immediately before or during the commission of the
offense/s with which one is charged. Also, to support the defense of insanity, it must be
shown that the accused had no full and clear understanding of the nature and consequences
of his or her acts.

In this case, Umawid relied solely on the defense of Dr. Quincina and Dr. Juliana to support
his claim of insanity. However, Dr. Quincina only examined Umawid six months before he
 committed the crime and three months and four months thereafter. Her findings as she
admitted did not include Umawid's mental disposition immediately before or during the
commission of the crimes. Also, given that Dr. Juliana failed to testify in favor of the accused,
Umawid's defense of insanity remained unsubstiantiateds, hence, he was properly adjudged
by the RTC and CA as criminally liable.

People vs Adriano & Samson

FACTS:

On 13 March 2007, at around 8:00 a.m., Police Officer 1 Matthew Garabiles (POI Garabiles) and
P02 Alejandro Santos (P02 Santos), in civilian clothes, were on their way to Camp Olivas,
Pampanga, riding a motorcycle along Olongapo-Gapan National Road.5

While they were at Barangay Malapit San Isidro, Nueva Ecija, a speeding blue Toyota Corolla
(Corolla) with plate no. WHK 635, heading towards the same direction, overtook them and the car
in front of them, a maroon Honda CRV (CRY) with plate no. CTL 957.6

When the Corolla reached alongside the CRV, the passenger on the front seat of the Corolla shot
the CRV and caused the CRV to swerve and fall in the canal in the road embankment. Four (4)
armed men then suddenly alighted the Corolla and started shooting at the driver of the CRV, who
was later identified as Cabiedes. During the shooting, a bystander, Bulanan, who was standing
near the road embankment, was hit by a stray bullet. The four armed men hurried back to the
Corolla and immediately left the crime scene. PO 1 Garabiles and P02 Santos followed the
Corolla but lost track of the latter.7

Later, both Cabiedes and Bulanan died from fatal gunshot wounds: Cabiedes was pronounced
dead on arrival (DOA) at the Good Samaritan General Hospital due to three (3) gunshot wounds
on the left side of his chest while Bulanan died on the spot after being shot in the head.

During the investigation, the police learned that the Corolla was registered under the name of
Antonio V. Rivera (Rivera). Upon inquiry, Rivera admitted that he is the owner of the Corolla but
clarified that the Corolla is one of the several cars he owns in his car rental business, which he
leased to Adriano. Later that day, Adriano arrived at Rivera's shop with the Corolla, where he was
identified by P02 Santos and PO 1 Garabiles as one of the four assailants who alighted from the
passenger's seat beside the driver of the Corolla and shot Cabiedes. He was immediately arrested
and brought to the Provincial Special Operations Group (PSOG) headquarters in Cabanatuan
City.8

In examining the crime scene, the Nueva Ecija Provincial Crime Laboratory Office recovered one
(1) deformed fired bullet from a .45 caliber firearm and five (5) cartridges from a .45 caliber
firearm.9

Ruling:
Nonetheless, Adriano is guilty of the death of Bulanan under Article 4 of the Revised
Penal Code,[23] pursuant... to the doctrine of aberratio ictus, which imposes criminal
liability for the acts committed in violation of law and for all the natural and logical
 consequences resulting therefrom. While it may not have been Adriano's intention to
shoot Bulanan, this fact will not... exculpate him. Bulanan's death caused by the bullet
fired by Adriano was the natural and direct consequence of Adriano's felonious deadly
assault against Cabiedes.

People vs Sabalones

People vs Albuquerque

Bataclan vs Medina

BATACLAN vs. MEDINA

FACTS:
Medina is the owner and operator of a bus. This bus, on Sept. 13, 1952 around 2:00AM somewhere in
Imus, Cavite, crashed and fell into a ditch. Apparently, its front tire burst, zig-zagged and turned turtle
into the ditch. Bataclan was one of the 18 passengers. Most of the passengers were able to get out,
but Bataclan and 3 others were trapped. It appears that the bus drivers and the passengers who
already got out did not try to help Bataclan et al get out, instead, about 10 of the locals in the area
came to their aid, they were carrying a burning torch for illumination, but then a fierce fire started and
engulfed the bus and killed Bataclan et al. It appears that there was a gas leak from the bus and it
caught fire from the torch the would-be rescuers were using.

The heirs of Bataclan sued Medina.

The trial court found that there was a breach of a contract of carriage where Medina undertook to take
Bataclan to his destination safely. The trial court also found that there was negligence on the part of
Medina since at the time of the blow-out, the bus was speeding. There is no question that under the
circumstances, the defendant carrier is liable. The only question is to what degree. The trial court
argued that Medina is only liable for the injuries suffered by Bataclan and not by his death, the
proximate cause of which was the fire, which was not caused by Medina.

ISSUE: Whether or not it was the negligence of Medina, owner of the bus company, which was the
proximate cause of the death of Bataclan.

HELD:
Yes. In this case, the proximate cause of the death was the overturning of the bus, because of the
overturning, it leaked gas which is not unnatural or unexpected. The locals coming to the aid of the
trapped passengers was most likely because the driver and the conductor went out looking for help. It
is only natural that the would-be rescuers bring with them a torch because it was 2:30AM and the
place was unlit. The fire could also be attributed to the bus driver and conductor because he should
have known, from the circumstances, and because he should have been able to smell gasoline and
therefore he should have warned the rescuers not to bring the torch. Said negligence on the part of
the agents of the carrier come under the codal provisions above-reproduced, particularly, Articles
1733, 1759 and 1763.
Proximate Cause that cause, which, in natural and continuous sequence, unbroken by any
efficient intervening cause, produces the injury, and without which the result would not have
occurred. And more comprehensively, the proximate legal cause is that acting first and producing the
injury, either immediately or by setting other events in motion, all constituting a natural and
continuous chain of events, each having a close causal connection with its immediate predecessor, the
final event in the chain immediately effecting the injury as a natural and probable result of the cause
which first acted, under such circumstances that the person responsible for the first event should, as
an ordinarily prudent and intelligent person, have reasonable ground to expect at the moment of his
act or default that an injury to some person might probably result therefrom.