Case Digest Criminal Law

People of the Philippines Vs. Antonio Oanis And

Alberto Galanta
July 27.1943
G. R NO. L- 47722
FACTS:

Captain Godofredo Monsod and Chief of Police Oanis were instructed to

arrest notorious criminal Balagtas and Irene, who was sleeping with her
paramour. Oanis and Galanta fired at Balagtas, but later discovered he was
an innocent citizen Tecson. Oanis and Galanta were charged with murder.
The trial court found them guilty of reckless imprudence, but the appellants
argue they acted innocently and did not incur criminal liability. They rely on
U.S. v. Ah Chong for their argument..

ISSUE:

Whether or not appellants are criminally liable for the death of Tecson.

HELD:

Yes. The crime committed by appellants is not merely criminal negligence,

the killing being intentional and not accidental.

An officer is justified in using force to secure and detain an offender, but they
cannot use unnecessary force or resort to dangerous means. Notoriety
should not justify precipitate action at the cost of human life. In the case of
Balagtas, the appellants found no circumstances that would prompt
immediate action, and could have made a bloodless arrest if necessary. The
crime committed is murder with the qualifying circumstance of alevosia.
However, a mitigating circumstance is the incomplete justifying
circumstance, which requires that the offender acted in the fulfillment of a
duty or lawful exercise of a right, and the injury or offense committed was
the necessary consequence of due performance. In this case, the appellants
acted in the performance of a duty and the crime was not the necessary
consequence of due performance.

People of the Philippines Vs. Cagoco

July 24.1932

Facts:

On July 24, 1932, Yu Lon and Yu Yee, father and son, were talking on a
sidewalk when a man approached them. Yu Lon was struck in the head,
causing him to fall backwards. His assailants fled, and Yu Yee pursued him
through various streets. Two other Chinese men, Chin Sam and Yee Fung,
joined him in the pursuit. The wounded man died at the Philippine General
Hospital. The accused argue they should be convicted of minor injuries
rather than murder.

Issue:

Whether or not the accused should only be charged with slight physical
injuries rather than murder

Held:

No. Since the accused struck the deceased from behind and without warning,
he acted with treachery. "There is treachery when the offender commits any
of the crimes against the person, employing means, methods, or forms in the
execution thereof which tend directly and especially to insure its execution,
without risk to himself arising from the defense which the offended party
might make." (Article 14, No. 16, of the Revised Penal Code.)

We have seen that under the circumstances of this case the defendant is
liable for the killing of Yu Lon, because his death was the direct consequence
of defendant's felonious act of striking him on the head. If the defendant had
not committed the assault in a treacherous manner, he would nevertheless
have been guilty of homicide, although he did not intend to kill the
deceased; and since the defendant did commit the crime with treachery, he
is guilty of murder.

People vs. Guillen (85 Phil 307) G.R. 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 President Manuel Roxas on March 10, 1947. He was sentence of
the trial court to death sentence. Julio Guillen has voted for the defeated
candidate in the Presidential elections held in 1946. Manuel Roxas assumed
presidency and according to Guillen, he became disappointed with President
Roxas for failure to redeem and fulfil promises made during elections which
led him to plan the assassination of the president. After some time planning,
he saw an opportunity on March 10, 1947 during a popular meeting held by
Liberal Party at 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 2 hand grenades which were given to him by an American
soldier in exchange for 2 bottles of whiskey. 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. The grenade exploded in the middle of a group of persons. Simeon
Valera was seriously injured and died the next day because of mortal wounds
caused as well as several other persons. Guillen was arrested and admitted
his responsibility.

ISSUE:

Whether or not the accused is guilty of only Homicide through Reckless

Imprudence with regard to the death of Simeon Valera and Less Serious
Physical Injuries with regard to the other persons injured

HELD:
In throwing the grenade towards the President with the intention of killing
him, the accused already acted with malice and is therefore liable for all the
consequences of his wrongful act. According to Article 4 of the RPC, criminal
liability is incurred by any person committing felony although the wrongful
act done be different from that which he intended. As held by the court, a
deliberate intent to do an unlawful act is inconsistent with the idea of
reckless imprudence. The sentence of the trial court is affirmed and death
sentence was executed in accordance to Article 81 of the RPC

Unites States Vs. Ah Chong

G R NO. L- 5272. March 19, 1910

Facts:

Ah Chong fatally stabbed his roommate, Pascual, thinking that he might be a

thief or a ladron that causes the death of Pascual. Ah Chong said that Pascual
didn’t identify himself when he asked who is trying to enter the room. He
admitted to the crime but argued that he had no intent of killing his
roommate, and he did it for his defense.

Issue:

Whether the defendant could be exempted from criminal liabilities given the
present circumstances.

Ruling:

Yes, there is no criminal liability provided always that the alleged ignorance
or mistake of fact was not due to negligence or bad faith.

Ignorance or mistake of fact can cancel the presumption of intent in criminal

cases, allowing for an acquittal unless the circumstances demand a
conviction under criminal negligence provisions. In this case, the defendant
Chinaman acted in good faith, believing the intruder was a thief, and was in
imminent peril. He acted in good faith, exercising his right of self-defense,
and was exempt from criminal liability if the facts were as he believed them
to be. He cannot be deemed guilty of negligence or recklessness in his
actions.

SULPICIO INTOD v. Court of Appeals, GR No.

103119, 1992-10-21

Facts:

In the morning of February 4, 1979, Sulpicio Intod, Jorge Pangasian, Santos

Tubio and Avelino Daligdig went to Salvador Mandaya's house... and asked
him to go with them to the house of Bernardina Palangpangan. Thereafter,
Mandaya and

Intod, Pangasian, Tubio and Daligdig had a meeting with Aniceto Dumalagan.
He told Mandaya that he wanted Palangpangan to be killed because of a land
dispute between them and that Mandaya should accompany the four (4)
men, otherwise, he would also be killed.

At about 10:00 o'clock in the evening of the same day,... Mandaya,

Pangasian, Tubio and Daligdig, all armed with firearms, arrived at
Palangpangan's house

At the instance of his companions, Mandaya pointed the location... of

Palangpangan's bedroom. Thereafter, Petitioner, Pangasian, Tubio and
Daligdig fired at said room. It turned out; however, that Palangpangan was in
another City and her home was then occupied by her son-in-law and his
family. No one was in the room when the accused fired the... shots. No one
was hit by the gun fire.

After trial, the Regional Trial Court convicted Intod of attempted murder.
Petitioner seeks from this Court a modification of the judgment by holding
him liable only for an impossible... crime

Issues:

Petitioner contends that, Palangpangan's absence from her room on the

night he and his companions riddled it with bullets made the crime
inherently impossible.

Ruling:

The case at bar belongs to this category. Petitioner shoots the place where
he thought his victim would be, although in reality, the victim was not
present in said place and thus, the petitioner failed to accomplish his end.

WE hereby hold Petitioner guilty of an impossible crime

Having in mind the social danger and degree of criminality shown by

Petitioner, this Court sentences him to suffer the penalty of six (6) months of
arresto mayor, together with the accessory penalties... provided by the law,
and to pay the costs.