US VS.

LAGNASON,
G.R. No. 1582, March 28, 1904, 3 Phil. 472

Facts:
Lagnason, the defendant, with his band, made an attack upon the pueblo of Murcia in the
Province of Occidental Negros but they were driven off by the force of Constabulary there
stationed. Two inspectors of the latter arrived with additional fortes and left the pueblo in search
of the defendant. A fight lasted an hour and a half which killed twenty of his men and two
policemen. Consequently, the defendant was captured in battle.

Issue: Whether or not the acts of Lagnason constitute?

Ruling:
Yes, the acts of violence committed by Lagnason and his band constitute treason.

Section 1 of Act No. 292 of the Philippine Commission provides that every person,
resident in the Philippine Islands, owing allegiance to the United States, or the Government of
the Philippine Islands, who levies war against them or adheres to their enemies, giving them aid
and comfort within the Philippine Islands or elsewhere, is guilty of treason. In this case, the
defendant’s organized attempt to overthrow and destroy the established government is a levying
of war against the government. It does not matter how vain and futile his attempt was. Lagnason
is guilty of treason.
LAUREL v. MISA
77 PHIL 856

FACTS:
Laurel was charged with treason during the Japanese occupation. He claims that he
cannot be tried for treason since his allegiance to the Philippines was suspended at that time.
Also, he claims that he cannot be tried under a change of sovereignty over the country since his
acts were against the Commonwealth which was replaced already by the Republic.

ISSUE: W/N absolute allegiance of the citizens suspended during Japanese occupation?

HELD/RATIO:
Laurel was found guilty. A citizen owes absolute and permanent allegiance to his
government or sovereign. No transfer of sovereignty was made; hence, it is presumed that the
Philippine government still had the power. Moreover, sovereignty cannot be suspended; it is
either subsisting or eliminated and replaced. Sovereignty per se wasn’t suspended; rather, it was
the exercise of sovereignty that was suspended. Thus, there is no suspended allegiance.
Regarding the change of government, there is no such change since the sovereign – the Filipino
people – is still the same. What happened was a mere change of name of government, from
Commonwealth to the Republic of the Philippines.
PEOPLE VS. ICARO
G.R. NO. L-2956

FACTS:
During the latter part of 1944, and early 1945, while the United States of America, the
Philippines, and the Allied Nations were at war with the Japanese Empire, Defendant Eleuterio
Icaro, a Filipino Citizen, owing faith and allegiance to both America and the Commonwealth of
the Philippines, openly adhered to the enemy, and gave it aid and comfort. Armed with a rifle,
and in company with other Filipinos and Japanese soldiers, also armed, and in company with
other Filipinos and Japanese soldiers, also armed, he took part in raids against guerilla suspects,
and in their arrest.
The Court of First Instance of Laguna, found him guilty of treason. He denies that he was
a Makapili.

ISSUE:
Can the Appellant be held guilty of Treason

RULING:
Yes. The point becomes unnecessary, since adherence to the enemy may be inferred from
the overt acts of treason committed by the appellant, consisting in the arrest of persons suspected
of being guerrillas who, with the exception of one Emilio Biscocho, were never seen again,
especially because the appellant was armed and in company with armed Japanese soldiers and
other Filipinos.
US vs BAUTISTA
6 Phil 581 (1906)

Facts: In 1903 a junta was organized and a conspiracy entered into by a number of Filipinos in
Hongkong, for the purpose of overthrowing the government of the United States in the
Philippine Islands by force of arms and establishing a new government.
Francisco Bautista (1), a close friend of the chief of military forces (of the conspirators) took part
of several meetings. Tomas Puzon (2) held several conferences where plans are made for the
coming insurrection; he was appointed Brigadier-General of the Signal Corps of the
revolutionary forces. Aniceto de Guzman (3) accepted some bonds from one of the conspirators.
The lower court convicted the three men of conspiracy. Bautista was sentenced to 4 years
imprisonment and a P3,000 fine; Puzon and De Guzman to 3 years imprisonment and P1,000.

Issue: WON the accused are guilty of conspiracy.

Held: Judgment for Bautista and Puzon CONFIRMED. Judgment for de Guzman REVERSED.
Yes, Bautista and Puzon are guilty of conspiracy. Bautista was fully aware of the purposes of the
meetings he participated in, and even gave an assurance to the chief of military forces that he is
making the necessary preparations. Puzon voluntarily accepted his appointment and in doing so
assumed all the obligations implied by such acceptance. This may be considered as evidence of
the criminal connection of the accused with the conspiracy.
However, de Guzman is not guilty of conspiracy. He might have been helping the conspirators
by accepting bonds in the bundles, but he has not been aware of the contents nor does he was, in
any occasion, assume any obligation with respect to those bonds.
Note: see RPC Art. 136: Crimes against public order: conspiracy and proposal to commit coup d’
etat, rebellion or insurrection.
PEOPLE VS PAAR
G.R. No. L-2318 March 31, 1950

Facts:

Between October 1944 and February 1945, Teofilo Paar worked as an undercover agent for the
Japanese Kempeitai in Baguio. He was seen in their uniform, armed with a .45 caliber pistol, and
participating in arrests. In December 1944, Paar turned over Melquiades Valdez to the
Kempeitai, leading to Valdez’s torture on charges of listening to U.S. radio broadcasts and
spreading information. He also played a role in the arrest and detention of Dr. Ireneo Solano,
accused of guerrilla activities and pro-American propaganda. Dr. Solano’s testimony was
supported by Felisa Caliao.

As a defense, Paar claimed he was only following orders from Major Laconico and did not
intend to betray his country. He argued that even if he participated in arrests, he was not guilty of
treason since there was no clear proof of adherence to the enemy.

Issue:

Did Paar’s overt acts satisfy the third element of treason, which requires the offender to either
levy war against the government or adhere to the enemy by giving aid or comfort.

Ruling:

The Supreme Court found Paar guilty of treason. The elements of treason are:

1. The offender is a Filipino citizen or an alien residing in the Philippines.

2. The Philippines is at war.
3. The offender either:
a. Levy war against the government, or
b. Adhere to the enemy by giving aid or comfort.

Paar was a Filipino, and the country was at war under Japanese occupation. His close association
with the Kempeitai, participation in arrests, and the suffering inflicted on detainees showed clear
adherence to the enemy. The Court rejected his defense, reasoning that if he was truly
undercover for the guerrillas, he had other means to accomplish his mission. Instead, his actions
demonstrated his deliberate choice to assist the enemy, believing Japan would win the war. His
overt acts—especially handing over civilians and providing intelligence—constituted both aiding
the enemy and adherence to them, thereby fulfilling the elements of treason.
PEOPLE VS MANGAHAS
93 Phil. 1113, G.R. Nos. L-5367 & L-5368, June 9, 1953

Facts:

On December 13, 1944, members of the Makapili, including Cayetano and Mariano Mangahas,
raided Lawang, Norzagaray. They surrounded the house of Enriqueta de la Merced and seized
food supplies meant for guerillas, including rice, canned beef, vegetables, salt, and other goods.
Witnesses Enriqueta de la Merced and Engracia de la Cruz testified to these acts.

On December 29, 1944, the Makapilis, including the defendants, looted the home of Primo S.
Cruz, taking rice, clothes, shoes, and other valuables. They also apprehended Cruz and brought
him to the San Jose garrison, after which he was never seen again. Similarly, Artemio Nicolas
was arrested and taken to the same garrison, as testified by their wives.

On December 30, 1944, the defendants, along with other Makapilis, arrested Moises Legaspi and
took him to their garrison. His wife and son testified to his capture. As a result, Cayetano and
Mariano Mangahas were charged with treason before the Court of First Instance in Bulacan.
They appealed the conviction.

Issue:

Were the defendants guilty of the crime of treason?

Ruling:

Yes, the Supreme Court upheld the conviction for treason. While the arrest of Primo S. Cruz and
Artemio Nicolas lacked the required two-witness rule, their capture still demonstrated adherence
to the enemy. The argument that there was no evidence linking the defendants to Moises
Legaspi’s arrest was rejected, as his wife and son confirmed their presence during the incident.

Additionally, the defendants’ participation in activities such as arresting guerillas, looting

supplies, sentry duties, military drills, and patrolling armed through the town were sufficient
proof of their allegiance to the enemy. Cayetano Mangahas' denial of involvement in the raid on
Enriqueta de la Merced’s house was outweighed by the testimony of eyewitnesses.
Consequently, the Supreme Court affirmed the lower court's decision.
PEOPLE VS. AGONCILLO
G.R. NO. L-985 JANUARY 23, 1948

FACTS:

In April 1944, the appellant sold about 300 kilos of alum crystals, at three pesos a kilo, to
the keribo, a construction company operated by the Japanese army. Two or three weeks
thereafter, he sold to the same entity some 100 pieces of water pipes, the price of which was not
known. About the third week of December, 1944, the appellant was seen on Jones Avenue
helping push a handcart full of truck and auto tires, batteries and spare parts into the intermediate
and high school premises then used by the Japanese Army as a motor pool.

ISSUE:

Whether or Not the Appellant committed treason for selling the alum crystals and water
pipes to the Japanese Army

RULING:

No. Even supposing that the appellant had really sold for a definite price alum crystals
and water pipes, the same did not per se constitute treason. As said articles were not exclusively
for war purposes, their sale did not necessarily carry an intention on the part of the vendor to
adhere to the enemy. The theory of the prosecution is that the sale was treasonable in view of the
other proven acts showing the appellant's adherence to the enemy. It appears, however, that the
alleged acts of adherence performed by the appellant took place after the overt act in question. It
is not unlikely that at the time the appellant made the sale, his motive was purely personal gain,
uninfluenced by any benefit inuring to the enemy. Where two probabilities arise from the
evidence, the one compatible with the presumption of innocence will be adopted. (People vs.
Agpangan, G.R. No. L-778, October 10, 1947.)
HAUPT VS UNITED STATES
MARCH 31, 1947

Facts

Hans Max Haupt, a naturalized U.S. citizen, was charged with treason for aiding his son, Herbert
Haupt, a German saboteur who entered the U.S. by submarine in June 1942 to disrupt American
war efforts. Hans sheltered Herbert, helped him secure a job at a military equipment
manufacturing plant, and assisted him in purchasing a car, actions that ultimately led to his
indictment.

Issues
1. Whether the overt acts alleged in the indictment constitutes treason under Article III,
Section 3 of the U.S. Constitution.
2. Whether the prosecution's evidence met the constitutional requirement of proof by two
witnesses to the same overt act.

Rulings:

1. The U.S. Supreme Court held that the overt acts alleged in the indictment, including
harboring and sheltering Herbert Haupt, assisting him in obtaining employment, and
helping him buy an automobile, constituted treason under Article III, Section 3 of the
U.S. Constitution.¹
2. The Court also held that the prosecution's evidence met the constitutional requirement of
proof by two witnesses to the same overt act, as there were multiple witnesses who
testified to Hans Haupt's involvement in harboring and aiding his son.
3. The Court affirmed the conviction of Hans Max Haupt for treason, upholding the
decision of the lower courts.
PEOPLE vs. EMILIANO CATANTAN
G.R. No. 118075. September 5, 1997

Facts:

Emiliano Catantan and Jose Macven Ursal were convicted of piracy and sentenced to life
imprisonment for hijacking a pumpboat owned by the Pilapil brothers in Cebu. Catantan
appealed, arguing that his actions constituted grave coercion rather than piracy, claiming they
didn't intend to permanently deprive the brothers of their vessel. However, the original
conviction found Catantan and Ursal guilty of piracy under Presidential Decree No. 532.

Issue:

Did the accused commit grave coercion or piracy under PD No. 532?

Ruling:

The Supreme Court upheld the reclusion perpetua sentence, affirming that Catantan was guilty
of piracy under PD No. 532. The Court clarified that piracy, as defined in Section 2(d) of PD
No. 532, involves the seizure of a vessel through violence or intimidation, regardless of
whether the intent was to permanently take possession of the boat. The forceful takeover of the
Pilapils' pumpboat while they were fishing clearly fell under this definition.

Furthermore, grave coercion, as defined in Article 286 of the Revised Penal Code, applies
when someone unlawfully forces another to do something against their will. However, the Court
emphasized that Catantan's act was not mere coercion but a violent seizure of a vessel in
Philippine waters, fitting the definition of piracy. The lack of physical evidence of the gun used
in the crime did not negate the fact that intimidation was employed to hijack the boat.

Thus, the conviction for piracy was affirmed.

PEOPLE VS TULIN
GR 111709, August 30, 2001

Facts: In the evening of March 2, 1991, "M/T Tabangao," a cargo vessel owned by the PNOC
Shipping and Transport Corporation, loaded with barrels of kerosene, regular gasoline, and
diesel oil, was boarded by 7 fully armed pirates. The pirates including the accused Roger P.
Tulin, Virgilio Loyola, and Andres Infante Jr. detained the crew and completely took over the
vessel. The vessel was directed to proceed to Singapore where the cargoes were unloaded,
transferred and sold under the direct supervision of accused Cheong San Hiong. Thereafter, the
captive vessel returned to the Philippines.

A series of arrests was thereafter effected and all the accused were charged with qualified piracy
or violation of Presidential Decree No. 532 (Piracy in Philippine Waters). They were
subsequently convicted of the crime charged. Hence, this appeal. Meanwhile accused Cheong
argues that the trial court erred in convicting and punishing him as an accomplice when the acts
allegedly committed by him were done or executed outside of Philippine waters and territory,
stripping the Philippine courts of jurisdiction to hold him for trial, to convict, and sentence.

Issue: Whether or not the Philippines has jurisdiction to try the crime committed in the instant
case.

Ruling:

Yes. As regards the contention that the trial court did not acquire jurisdiction over the person of
accused-appellant Hiong since the crime was committed outside Philippine waters, suffice it to
state that unquestionably, the attack on and seizure of "M/T Tabangao" (renamed "M/T Galilee"
by the pirates) and its cargo were committed in Philippine waters, although the captive vessel
was later brought by the pirates to Singapore where its cargo was off-loaded, transferred, and
sold. And such transfer was done under accused-appellant Hiong's direct supervision. Although
Presidential Decree No. 532 requires that the attack and seizure of the vessel and its cargo be
committed in Philippine waters, the disposition by the pirates of the vessel and its cargo is still
deemed part of the act of piracy, hence, the same need not be committed in Philippine waters.

Moreover, piracy falls under Title One of Book Two of the Revised Penal Code. As such, it is an
exception to the rule on territoriality in criminal law. The same principle applies even if Hiong,
in the instant case, were charged, not with a violation of qualified piracy under the penal code
but under a special law, Presidential Decree No. 532 which penalizes piracy in Philippine waters.
Verily, Presidential Decree No. 532 should be applied with more force here since its purpose is
precisely to discourage and prevent piracy in Philippine waters (People v. Catantan, 278 SCRA
761 [1997]). It is likewise, well-settled that regardless of the law penalizing the same, piracy is a
reprehensible crime against the whole world (People v. Lol-lo, 43 Phil. 19 [1922]).
PEOPLE vs LO-LO and SARAW
G.R. No. 17958 February 27, 1922

Facts:
Two boats containing several people were on navigation for a number of days when they
were surrounded by several armed men. These men first asked only for food, but once aboard the
boat they took all the cargoes, attacked some men, and brutally violated two women. Thereafter,
most of the people were left on the boat and holes were made by the armed men in the idea that it
would submerge.

Lol-lo who raped one of the women and Saraw were able to escape. Upon their return to
Sulu, Philippines Islands they were arrested and were charged in the Court of First Instance of
Sulu with the crime of piracy. A demurrer was interposed by counsel de officio for the Moros,
based on the grounds that the offense charged was not within the jurisdiction of the Court of First
Instance, nor of any court of the Philippine Islands.

Issue:
Whether CFI of Sulu can have jurisdiction over the case

Decision:
Yes, CFI of Suli can have jurisdiction over the case.

In one case decided by the Supreme Court (U.S. vs. Furlong [1820], 5 Wheat., 184.), it
was ruled that Pirates are in law hostes humani generis. Piracy is a crime not against any
particular state but against all mankind. It may be punished in the competent tribunal of any
country where the offender may be found or into which he may be carried. The jurisdiction of
piracy unlike all other crimes has no territorial limits. As it is against all so may it be punished by
all. Nor does it matter that the crime was committed within the jurisdictional 3-mile limit of a
foreign state, for those limits, though neutral to war, are not neutral to crimes.

Here, Lol-lo and Saraw committed the crime on Dutch East Indies waters but were
apprehended only in Sulu, Philippines.

Therefore, CFI of Sulu has jurisdiction over the case as it is a competent tribunal where
the offenders were apprehended.
PEOPLE VS MISA
CA 36 OG 3496

Facts:
The chief of police rearrested a woman who had been released by means of a verbal order of the
justice of the peace. Without verifying the order of release, the accused proceeded to make the
re-arrest. He is charged with arbitrary detention. The accused claimed that he acted without
malice.

Issue:
Whether or not the accused committed arbitrary detention by rearresting a woman who had been
previously released by a justice of the peace's verbal order.

Ruling:

The chief of police committed arbitrary detention through simple imprudence provided for and
punished under Article 365, paragraph 2 of the Revised Penal Code in connection with Article
124 paragraph 1 of the same Code.
Periods of detention penalized
a) If the detention has not exceeded 3 days
b) If the detention has continued more than 3 days but not more than 15 days
c) If the detention has continued more than 15 days but not more than 6 months.
d) If the detention has exceeded 6 months (art 124 Nos 1 to 4)
PEOPLE vs. GUNGON
G.R. No. 119574 March 19, 1998

FACTS

On January 12, 1994, Agnes Guirindola was flagged down by a man impersonating a traffic
officer, later identified as Venancio Roxas. After complying, she allowed Roxas into her car,
where he initially took a bribe but soon after, with the help of Roberto Gungon, forcibly detained
her. The men attempted to drug her, and she eventually lost consciousness. Upon waking, she
found herself robbed of her valuables and accompanied by a third unidentified man. Later, while
stopping in a deserted area to relieve herself, she was shot by Roxas and left for dead. Gungon
was ultimately convicted of robbery in court.

ISSUE

Whether or Not Gungon was correctly convicted with robbery.

RULING
Article 293 of the Revised Penal Code defines robbery as unlawfully taking another's
property with intent to gain, using violence, intimidation, or force. Since the accused took the
victim’s jewelry and cash without these elements, the act was reclassified as theft under
Article 308 and Article 309. The court modified the conviction and sentenced the accused to
a prison term of up to nine years, eight months, and one day. Additionally, it upheld related
case rulings and forwarded the records to the Office of the President for possible clemency.
US vs BATALLONES
23 Phil. 46

Facts:
Two Bureau of Internal Revenue secret service agents, strangers in the municipality, were seen
acting suspiciously near the marketplace. The accused, two policemen, called upon them to give
an account of themselves and explain their suspicious conduct, and at the same time demanded
that they produce their cedulas, which the agents were unable to do. Believing that their conduct
and inability to satisfactorily account for themselves justified the suspicion that they were in
some way connected with the recent robberies in the place, or that they were about to commit
theft or robbery, the accused placed the two men under arrest and took them forthwith to the
house of the justice of the peace, accused Battalones, informing the latter of the arrest of the two
men with them and asking him to decide what was proper to do. The justice of the peace, without
verifying the truth of the claims of the agents that they were of the Bureau of Internal Revenue,
ordered them taken to the municipal jail to be detained until further orders.

Issue:
Whether or not there is a charge of arbitrary detention.

Held:
No charge of arbitrary detention can be maintained against the two policemen. In the light of
after events, the suspicion directed against the secret service agents was not well founded, but
viewing the facts as they must have presented themselves to the policemen at the time of the
arrest, they must be held to have had reasonable grounds upon which to base their suspicions as
to the arrested men. But the justice of the peace who arbitrarily and without investigation
directed the detention of the agents was held guilty of the crime of "detention arbitraria" through
negligence. The justice of the peace was not actuated by any special malice or ill-will toward the
prisoners, but he was willfully negligent of their rights.
VILLAVICENCIO vs. LUKBAN
CASE NO. 39

FACTS:
Manila Mayor Justo Lukban ordered the forced relocation of around 170 women of ill repute to
Davao between October 16 and 25, 1918. Without their consent, police officers removed them
from their homes, placed them on steamers, and sent them to work as laborers. The women were
unaware of their destination and had no chance to refuse or gather their belongings.

ISSUE:
Whether the women were illegally restrained of their liberty by being forcibly relocated.

HELD:
Yes. The court ruled that the forced transfer violated the women's right to liberty. The writ of
habeas corpus applies to all forms of involuntary restraint, and the officials had no legal authority
to compel citizens to change their domicile. The act was equivalent to unlawful detention.
PEOPLE VS GERONIMO
100 Phil 90

Facts:

Federico “Commander Oscar” Geronimo and others were charged with complex rebellion,
including murders, robberies, and kidnappings, as part of a conspiracy between the Communist
Party of the Philippines (CPP) and Hukbong Mapagpalaya ng Bayan (HMB). The HUKS
ambushed Mrs. Aurora A. Quezon’s convoy, killed government officials, kidnapped a cashier to
steal ₱80,000, raided and killed a police officer, and attacked an army patrol. Geronimo also
executed a local official. Initially pleading not guilty, he later changed to guilty, leading to a life
sentence recommendation. His defense argued the crimes were part of rebellion and should be
downgraded to simple rebellion.

Issue:

Whether the crimes committed were a complex crime of rebellion with murders, robberies, and
kidnappings.

Ruling:

No, the court ruled it was simple rebellion. Acts of violence are not automatically absorbed into
rebellion unless committed for political purposes. If done for personal gain, they are separately
punishable. Even then, they do not form a complex crime with rebellion, as they are not
necessary for its commission.
CARIÑO vs.PEOPLE
G.R. No. L-14752 April 30, 1963

Facts:

The petitioner allegedly acted as an accomplice of the Communist Party of the

Philippines who provided food and other supplies to the rebels per the request of his friend who
was a top leader of the organization. He was also approached by a member of the special unit of
CPP to aid in the conduct of loots and hold-ups to raise funds for the CPP. Francisco also
changed the money obtained from those loots into pesos and assisted in opening an account in
the bank where he works as a ranking employee.

Issue:

Whether or not the petitioner was an accomplice in the crime of rebellion by the
Communist Party of the Philippines (CPP).

Ruling:

No, Francisco was not an accomplice. The Supreme Court held that the above mentioned
acts of the appellant did not constitute acts of cooperation in the execution of the act of
overthrowing the government. If appellant's acts may be considered an indirect help or aid in the
rebellion, the same cannot constitute acts of uprising or rebellion.

In People vs. Tamayo, the Supreme Court ruled that for a person to be considered an
accomplice in a crime like insurrection or rebellion, their actions must significantly contribute to
its success. Providing food supplies, converting foreign currency to pesos, or assisting rebels in
opening accounts do not necessarily indicate an intent to support the rebellion. Since Francisco's
assistance to the communists did not meet this threshold, he was not proven to be an accomplice
by the CPPs.
PEOPLE VS DAIG
GR No. 100231, April 28, 1993

Facts:

On August 4, 1987, Pfc. Manatad, Pfc. Tizon and Pfc. Catamora were assisting in
canning the traffic at M.N. Briones and Bonifacio Streets in Mandaue City. At about 4 pm, Pfc.
Catamora noticed 8 persons, one of whom is Edwin Nuñez, acting suspiciously. They ended up
in an gun battle that resulted to the death of Pfc. Manatad. The defendants were able to escape
but were apprehended after 12 days.

Dasig confessed that he and the group of Nuñez, acting killed Pfc. Manatad, but contends
that he should be convicted of simple rebellion and not murder with direct assault.

Issue:

Whether or not defendant is guilty of rebellion and not murder with direct assault.

Held:

Yes. Art. 135 of the RPC defines rebellion as a crime of taking up arms against the
government.

In this case, Dasig not only confessed voluntarily his membership with the sparrows unit
but also his participation and that of his group in the killing of Pfc. Manatad while manning the
traffic. The sparrow unit is the liquidation squad of the NPA with the objective of overthrowing
the duly constituted government. The killing of Pfc. Manatad was committed as a means to or in
furtherance of the subversive ends of the NPA. The killing of a police officer is included as an
act done in furtherance of rebellion.
PEOPLE VS AVILA
G.R. No. 84612 March 11, 1992

Facts:
On October 23, 1985, Governor Murillo was assassinated in Tandag, Surigao del Sur by Avila,
who shot him in the head with a .45 caliber pistol while inside a car. His accomplice, Agrabio,
was present, while a co-accused, Silvoza, was absent due to illness. After the shooting, Avila and
Agrabio fled.
During the trial, the defense claimed the killing was part of rebellion, as the accused were
members of the New People's Army (NPA) and acted on orders from Commander Celo to
"liquidate" the Governor due to alleged corruption. However, the trial court convicted Avila and
Agrabio of murder on July 12, 1988, ruling that no active rebellion or combat was ongoing at the
time of the crime. Instead, the evidence showed a targeted assassination, not an act of rebellion.
Silvoza was acquitted.
Issue:
whether the trial court correctly convicted appellants of the crime of murder.

Held:
In the instant appeal, while we find the appellants guilty of rebellion, we also find that their case
falls under the "second group" referred to in paragraph two (2) of Article 135, the evidence
having shown that they belonged to the liquidating squad of the NPA, tasked to operate in
Tandag, and that they killed the victim, Governor Murillo, in compliance with the orders of their
senior officer, one Commander Celo of the NPA. -Hence, this Court is of the view that the
appellants committed the crime of simple rebellion, not murder, punishable under Article 134
and 135 of the Revised Penal code
US VS. TUBIANA
G.R. NO. L-11847 | FEBRUARY 1, 1918

FACTS:

On February 23, 1915, a neighbor of Tabiana obtained a warrant from Canillas for the
arrest of Tabiana and his herdsman for a trivial misdemeanor involving trespass by Tabiana’s
cattle. The warrant was executed by two policemen, Emiliano Callado and Baltazar Cabilitasan.
At 4 p.m., the policemen found Tabiana in the countryside. Tabiana expressed irritation but
agreed to report to the municipal building later with his herdsman. At 6 p.m., Tabiana had not
appeared, so the policemen were instructed to bring him in. They found him at his house with
friends. Tabiana reluctantly agreed to accompany them. Tabiana was acquitted of the original
trespass charge but was prosecuted for attack upon agents of public authority under Article 249
of the Penal Code.

ISSUE:

Whether the defendants, Gelasio Tabiana and Julian Canillas, are guilty of attack upon
agents of public authority under Article 249 of the Penal Code.

RULING:

NO. The Supreme Court modified the decision of the Court of First Instance Gelasio
Tabiana was found guilty of resistance and serious disobedience under Article 252 of the Penal
Code, not the more serious offense under Article 249. Julian Canillas was also found guilty of
the same offense, as he participated in the resistance knowing Tabiana was liable to arrest under
a warrant he issued. Both defendants were sentenced to two months and one day of Arresto
mayor and a fine of P125, with accessory penalties and subsidiary imprisonment in case of
insolvency.
21 THE UNITED STATES V. NICOMEDES GUMBAN
G.R. No. L-13658, November 9, 1918

FACTS:
Petronilo Gumban, the Municipal President of Jaro, was informed by a councilor about issues
concerning quarantined animals in the barrio of Pavia. While inspecting the area, a tenant named
Ismana reported that he had caught a carabao belonging to Policarpio Gumban, Petronilo’s
brother, damaging a planted area. Ismana seized the carabao and took it to the police station.
When Epifanio and Nicomedes Gumban, the carabao’s owners and Petronilo’s brothers, arrived,
they protested the seizure. Petronilo deemed the action justified but agreed to consult the
quarantine officer. Upon learning that the carabao could not be released, Nicomedes became
enraged, insulted Petronilo, and slapped him on the face, striking his left ear. As a result,
Nicomedes was charged with “assault upon agents of authority.”
ISSUE: Whether or not the accused must be charged with assault upon agents of authority (Art.
249) or assault with hands upon a person in authority (Art. 250).

HELD:
The case qualifies as an assault upon a person in authority rather than merely an assault upon an
agent of authority. The fiscal's classification of the crime as an assault on an agent of authority is
incorrect because a municipal president is considered a person in authority. However, this
misdesignation does not affect the validity of the information, as the crime is determined by the
facts stated rather than the fiscal’s classification. Although the fiscal describes the municipal
president as an agent of authority, this is a legal conclusion that can be disregarded. The mere
allegation that the offended party was a municipal president is sufficient to establish that the
charge pertains to assault upon a person in authority.
22 PEOPLE VS ABALOS
258 SCRA 523, July 9, 1996

Facts:
On March 20, 1983, during a barangay fiesta Police Major Cecilia Abalos and the
defendant Tiburcio Abalos, his son, had a heated argument. The victim, Pfc. Sofronio Labine
arrived at the scene to stop the fight. He was struck in the head with a piece of wood by the
defendant. He immediately fled from the scene.
Issue:
Whether or not the defendant is guilty of complex crime of Direct Assault with Murder.
Held:
Yes. He is guilty of the second mode of Art. 148 of the RPC. All of the elements of
Direct Assault were present in this case. When the assault results in the killing of that agent or of
a person in authority, there arises the complex crime of Direct Assault with Murder or Homicide.
The killing in the instant case constituted the felony of murder qualified by alevosia through
treacherous means. Pfc. Labine was struck from behind. Labine was a duly appointed member of
INP in Catbalogan, Samar and thus, was an agent of a person in authority pursuant to Art. 152 of
the RPC. He was also in the actual performance of his duties when assaulted by the defendant,
and was wearing his uniform.
23 PEOPLE VS RILLORTA
180 SCRA 102

FACTS:
Romy Ramos, a thresher operator, testified that Pascual Rillorta threatened him with a gun,
resenting the threshing of palay in his barrio by outsiders. Later, as Ramos and his group were
leaving, Pascual and his sons, Wesley and Wilson, stopped them and warned them not to return.
Barangay Captain Emiliano Doton intervened but was chased by the three accused. They
surrounded him, pushed him toward a creek, and Pascual hacked him with a bolo while his sons
restrained him. Doton cried out for help before being killed. Pascual denied the killing, claiming
self-defense, while Wesley stated he only defended his father.

ISSUE:
Whether or not Barangay Captain Doton was performing his official duties as barangay captain
when attacked.

HELD:
YES. Under Article 152 of the Revised Penal Code and P.D. 299, a barangay captain (formerly a
"barrio lieutenant") is a person in authority. When Doton intervened to prevent a violent
encounter between the Pascual Rillorta and Ramos' group, he was discharging his duty as
barangay captain to protect life and property and enforce law and order in his barrio.
24 US vs. LOO HOE
G.R. No. 12473, September 18, 1917

Facts:
Loo Hoe, previously convicted of violating the Opium Law in the Philippines, was sentenced to
deportation. After being deported, Loo Hoe returned to the Philippines, violating the deportation
order.
Issue:
Whether or not violating a deportation order constitute contempt of court under Section 232 of
Act No. 190.
Ruling:
The Supreme Court ruled that violating a deportation order does not constitute contempt of court.
The lower court's conviction was reversed, and Loo Hoe was ordered to be turned over to
executive authorities for re-execution of the original deportation order.
25 PEOPLE VS PADILLA
G.R. No. L-56218 Oct 23, 1984

Facts:
On the evening of April 20, 1978, Padilla and Superable, after consuming half a gallon
of tuba (local wine), went to the house where Carmen was staying. They forcibly entered the
house, grabbed Carmen, and dragged her out despite resistance from Carmen and her aunt,
Cresencia Solano. Padilla boxed Carmen, causing her to fall, while Superable threatened both
Carmen and Cresencia with a small bolo (pisao). The two accused warned that anyone who tried
to help Carmen would be killed. Carmen was raped by Superable three time while Padilla stood
guard. He uses bolo to threaten her. Carmen underwent a medical examination, which revealed
multiple injuries, hymenal laceration and other signs consistent with sexual assault. Gaudencio
Padilla went into hiding and was eventually apprehended in a hospital where he was using a
fictitious name after undergoing an appendectomy while Rogelio Superable was initially arrested
but later escaped.

Issue:
1. Whether Gaudencio Padilla conspired with Rogelio Superable in the commission of the
crime of forcible abduction with rape.
2. Whether Padilla directly participated in the abduction and cooperated in the
commission of the rape.

Ruling:
The Supreme Court affirmed the decision of the trial court, finding Gaudencio Padilla guilty as
a co-principal in the crime of forcible abduction with rape. The Court increased the award
for moral damages from P10,000.00 to P30,000.00. The Court held that Padilla’s actions,
including standing guard during the rape and participating in the abduction, established
his conspiracy with Superable.
26 PEOPLE VS CORRAL
G.R. No. 42300 Jan 31, 1936

Facts:
The appellant, Amadeo Corral, was charged with illegal voting during the general elections held
on June 5, 1934, in Davao, Philippines. He was convicted for voting while under a legal
disqualification under Section 432 of the Revised Administrative Code. Amadeo Corral was
sentenced by final judgment on March 3, 1910, to eight years and one day of presidio mayor (a
form of imprisonment). There was no evidence that he had been granted a plenary pardon before
June 5, 1934. Despite his disqualification, Corral voted in the June 5, 1934, general elections in
Precinct No. 18, Davao. Corral was prosecuted under Section 2642 of the Revised
Administrative Code, which penalizes illegal voting with imprisonment, a fine, and
disqualification from suffrage and public office.
The trial court convicted him, and he appealed the decision.
Issue:
1. Whether Amadeo Corral was legally disqualified from voting under Section 432 of the
Revised Administrative Code.
2. Whether the disqualification imposed by Section 432 is permanent or limited to the
duration of the sentence.
3. Whether Corral’s prior voting in 1928 rendered his offense in 1934 prescribed.
4. Whether the disqualification is a form of punishment or a protective measure.

Ruling:
The Supreme Court affirmed the conviction of Amadeo Corral. The Court held that:
1. Corral was disqualified from voting under Section 432 of the Revised Administrative
Code because he had been sentenced to more than 18 months of imprisonment and had
not received a plenary pardon.
2. The disqualification is not a punishment but a protective measure to preserve the integrity
of elections.
3. The disqualification is not limited to the duration of the sentence but continues unless
removed by a plenary pardon.
 4. Corral’s prior voting in 1928 did not absolve him of liability for illegal voting in 1934.

27
28 US vs Solito
G.R. No. L-12546 August 17, 1925

Facts:

Mariano Solito was a correspondence clerk and acting chief clerk in the office of the division
superintendent of schools in the municipality of Dumaguete. As clerk, he was entrusted with the care of
the correspondence of said office, and was authorized to open letters of an official character addressed to
the office. It was the custom to the Director of Education to forward to the division superintendents of
schools checks for the reimbursement for travel expenses and for the payment of the salary of employees.

On April, 19, 1915, a warrant was issued to Alvah D. Riley for the sum of P657.53 by the Auditor of the
Philippine which was directed to the Treasurer of the Philippines. That on the same day said warrant was
also sent to the Director of Education. However, the defendant presented said warrant to the municipal
treasurer for payment and a note purported to have been written and signed by Riley, in which the latter
requested the said treasurer to cash the warrant. Riley denies absolutely that he gave to the defendant said
note. The note was a forgery. Riley never signed it nor authorized it.

Issue:

Do these acts of the defendant fall under any of the provisions of Act No. 1754? Is the defendant
punishable under any of said provisions?

Held:

The warrant, originally issued by the Government of the Philippines as an obligation under Act
No. 1754, was payable to Alvah D. Riley or his order. However, the defendant endorsed it in a
way that effectively removed the "or order" restriction, making it payable to bearer instead. This
alteration was material, as it changed the nature of the check from one requiring Riley’s
endorsement for negotiation to one that could be transferred by mere delivery. Any unauthorized
modification of a check’s payability, such as changing "or order" to "bearer," constitutes a
material alteration. In determining whether an endorsement alters a financial instrument, both the
endorsement and the original terms of the document must be considered. Since the defendant
knowingly passed and used a fraudulently altered government obligation, he is liable for
violating Article 4 of Act No. 1754.
29 PEOPLE VS PADILLA
G.R. No. L-56218 Oct 23, 1984

Facts:
On the evening of April 20, 1978, Padilla and Superable, after consuming half a gallon
of tuba (local wine), went to the house where Carmen was staying. They forcibly entered the
house, grabbed Carmen, and dragged her out despite resistance from Carmen and her aunt,
Cresencia Solano. Padilla boxed Carmen, causing her to fall, while Superable threatened both
Carmen and Cresencia with a small bolo (pisao). The two accused warned that anyone who tried
to help Carmen would be killed. Carmen was raped by Superable three time while Padilla stood
guard. He uses bolo to threaten her. Carmen underwent a medical examination, which revealed
multiple injuries, hymenal laceration and other signs consistent with sexual assault. Gaudencio
Padilla went into hiding and was eventually apprehended in a hospital where he was using a
fictitious name after undergoing an appendectomy while Rogelio Superable was initially arrested
but later escaped.

Issue:
1. Whether Gaudencio Padilla conspired with Rogelio Superable in the commission
of the crime of forcible abduction with rape.

2. Whether Padilla directly participated in the abduction and cooperated in the

commission of the rape.

Ruling:
The Supreme Court affirmed the decision of the trial court, finding Gaudencio Padilla guilty as
a co-principal in the crime of forcible abduction with rape. The Court increased the award
for moral damages from P10,000.00 to P30,000.00. The Court held that Padilla’s actions,
including standing guard during the rape and participating in the abduction, established
his conspiracy with Superable.
30 Enemecio v. Office of the Ombudsman
G.R. No 146731 January 13, 2004

Facts:

Agustina M. Enemecio, a utility worker at CSCST-CFT, filed administrative and criminal

complaints against Assistant Professor Servando Bernante for misconduct, falsification,
malversation, dishonesty, and defamation. She accused him of spray-painting obscene words
about her, shouting defamatory remarks, and falsifying leave records to hide a prison sentence.
The Ombudsman dismissed both complaints for lack of merit.

Enemecio then filed a certiorari petition with the Court of Appeals, challenging the
Ombudsman’s dismissal of the criminal case. However, the appellate court rejected her petition,
citing Fabian v. Desierto, ruling that her remedy was a petition for review under Rule 43, not
certiorari under Rule 65. Enemecio argued that certiorari was her only option, but the court held
that the Supreme Court had jurisdiction over Ombudsman decisions in criminal cases under RA
6770, leading to the dismissal of her petition.

Issue: Whether or not petitioner availed of the wrong remedy

Held:
Yes. The Court of Appeals clarified that Fabian v. Desierto does not apply to Enemecio’s
petition, as it only concerns administrative disciplinary actions. However, her petition still failed
because she used the wrong remedy. Appeals from Ombudsman decisions in administrative
cases should be filed under Rule 43 with the Court of Appeals, while certiorari petitions
challenging probable cause findings in criminal cases should go to the Supreme Court under
Rule 65. Since Enemecio filed her certiorari petition with the wrong court, her petition was
dismissed for lack of merit.
31_ Lastrilla v Granda

Facts:

Granda accused Lastrila and his associates of falsifying three deeds of sale to fraudulently
acquire land originally owned by Granda’s grandparents, who passed away in 1989 and 2000.
These falsified deeds led to the registration of the lands under Lastrila and his relatives' names
The deeds allegedly contained forged signatures, were backdated to 1985 despite transactions
occurring in 1999–2000, and included an invalid witness. The City Prosecutor charged Silvina
and lawyer Camenforte but excluded Lastrila. Granda appealed, and while the DOJ upheld the
prosecutor’s decision, the Court of Appeals ruled that Lastrila should also be charged with
falsification. Lastrila contested this, arguing that he paid ₱18 million for the land, which he
claimed negated liability.

Issue: was there probable cause to engender the belief that petitioner is one of the authors of the
falsification?

Held: There was probable cause in the case. Lastrilla claimed that the grandparents signed the
deeds in his presence in 1985, but he admitted that negotiations for the sales only began in 1998,
raising doubts about the authenticity of the documents. Additionally, the PNP Crime Lab found
that the grandparents’ signatures did not match their known specimens. The Court rejected
Lastrilla’s argument that no harm was done, emphasizing that falsification of public documents
is punishable not for financial gain or injury to others but for violating public trust and distorting
the truth. The case establishes that each falsified document constitutes a separate count of
falsification, regardless of the number of properties listed within it. Since three deeds of sale
were falsified, Lastrilla and his accomplices faced three counts of falsification. However,
multiple falsification methods within a single document still amount to only one offense per
document. Lastly, under Article 171, Paragraph 2, the case clarifies that falsification applies even
if the persons falsely represented in the document were already deceased.
32 US v. Romero
G.R. No. L-5805, September 16, 1910

Facts:
The accused, Romero, was charged with the crime of brigandage under Act No. 518. He was
alleged to be part of an armed band that roamed the countryside, committing robberies and other
criminal acts. The prosecution presented evidence that Romero was a member of an outlaw
group engaged in violent activities against local communities. However, Romero denied his
involvement, claiming he was merely in the vicinity but did not participate in the group's crimes.
Issue:
Whether or not Romero was guilty of brigandage under Act No. 518.
Ruling:
The Supreme Court convicted Romero, holding that mere membership in an armed band engaged
in robbery and lawlessness was sufficient to establish guilt under the brigandage law. The court
ruled that actual participation in specific robberies was not necessary; rather, proof that the
accused was part of a group with the intent to commit robbery or other lawless acts was enough
for conviction. The purpose of Act No. 518 was to suppress organized crime and ensure public
safety. Thus, Romero was found guilty of brigandage and sentenced accordingly.
33. Ark Travel Express, Inc. v. Abrogar, et al.,
G. R. No. 137010, August 29, 2003, 410 SCRA 149.

FACTS:
Ark Travel Express, Inc. (Ark Travel) filed a criminal complaint against Violeta Baguio and
Lorelei Ira for False Testimony in a Civil Case under Article 182 of the Revised Penal Code
before the City Prosecutor of Makati. The City Prosecutor found probable cause and filed the
necessary charges against them before the Metropolitan Trial Court (MTC).
The private respondents sought a review of this decision with the Department of Justice (DOJ),
which ruled in their favor, leading the Makati Prosecution Office to file a Motion to Withdraw
Information before the MTC. However, Ark Travel submitted an Urgent Petition for Automatic
Review to the DOJ, which reversed its earlier ruling and ordered the City Prosecutor to continue
the prosecution. Consequently, the MTC denied the Motion to Withdraw Information.
Baguio and Ira then filed a Motion for Reconsideration with the DOJ, which was granted. They
also requested the MTC to reconsider its order, arguing that there were no legal obstacles to
withdrawing the charges, but the MTC denied their motion.
Seeking relief, the private respondents filed a petition for certiorari under Rule 65 before the
Regional Trial Court (RTC) of Makati, which ruled in their favor. Ark Travel’s motion for
reconsideration was denied, prompting them to file the present petition for certiorari before the
Supreme Court.

ISSUE/S:
whether the Regional Trial Court (RTC) committed grave abuse of discretion by nullifying the
Metropolitan Trial Court’s (MTC) orders, prohibiting it from hearing Criminal Cases Nos.
200894 and 200895, and ordering their outright dismissal.

HELD:
The Supreme Court ruled that when a trial court is confronted with a motion to withdraw
an Information due to lack of probable cause based on a DOJ resolution, it must independently
assess the merits of the motion. The trial court is not bound by the DOJ’s ruling but must
evaluate it before proceeding with the trial.
In this case, the Metropolitan Trial Court (MTC) failed to conduct an independent
assessment and merely relied on the DOJ’s contradicting rulings. This constituted grave abuse of
discretion, justifying the Regional Trial Court’s (RTC) intervention. However, the RTC
exceeded its jurisdiction by considering the criminal cases as withdrawn, effectively dismissing
them without evaluating probable cause, which was beyond the issue presented before it.
The Supreme Court nullified both the RTC’s orders declaring the cases withdrawn and
the MTC’s orders issued without proper assessment. The MTC was directed to suspend the
criminal proceedings until a final decision is reached in the related civil case pending before the
RTC.
 US v. Soliman
Jan 6, 1917 G.R. No. 11555

FACTS:

Gabino Soliman, the defendant/appellant, was found guilty for false testimony (perjury) in
another criminal case, for falsely imputing to some other persons the commission of the crime of
estafa. The trial judge on the ground that there was room for reasonable doubt acquitted him.
However, appellant was sentenced to 6 months imprisonment and P300 fine was imposed by the
trial judge for there can be no doubt that the accused was guilty of the crime of perjury as
defined and penalized in Act No. 1697 Sec.3.

The enactment of the Administrative Code (Act No. 2657) was alleged to have expressly
repealed Act No. 1697 Sec.3 where the former became effective on July 1, 1916. On the other
hand, the judgment was entered on November 23, 1915. It was suggested that the repealed Act
No. 1697 Sec.3 should be held to have the effect of remitting and extinguishing the criminal
responsibility of the accused incurred under the provisions of the repealed law prior to the
enactment of the Administrative Code.

ISSUE:

WON the enactment of Administrative Code repealing Act No. 1697 Sec.3 relieved Soliman of
his penalties.

HELD:

The repeal of Act No. 1697 did not automatically absolve offenders from penalties under the old
law unless the new law reduced or eliminated the penalty, in which case the offender would
benefit from the more lenient provisions. The court did not presume that the legislature intended
to leave false swearing in court unpunished, which would have been the consequence of the
repeal unless it revived the older law (Act No. 2142). According to the Administrative Code (Act
No. 2657, Sec. 12), a repealed law is not revived unless explicitly stated. The court ruled that the
express repeal of Act No. 1697 revived the Penal Code's provisions on perjury, which had been
implicitly repealed. Since Act No. 2142 prescribed a lesser penalty, the accused, Soliman, was
entitled to its benefits. Courts still have jurisdiction over offenses committed before a law is
repealed unless the new law entirely decriminalizes the act. The court concluded that when a new
law replaces an old one with different penalties, the more favorable penalty must be applied to
the accused. Thus, while the conviction was affirmed, the sentence was reduced to 4 months and
1 day of arresto mayor and a fine of P75, with subsidiary imprisonment as prescribed by law.
35 PEOPLE VS. ANGANGCO

G.R. NO. L-17169 | NOVEMBER 30, 1963

FACTS:

Charges Against Respondents: On April 4, 2005, the Deputy Ombudsman for Luzon
(OMB-Luzon) found probable cause to indict the respondents for the following offenses: Leila
Ang: Falsification of Public Documents (Criminal Case No. 2005-1046). Leila Ang, Rosalinda
Driz, Joey Ang, Anson Ang, and Vladimir Nieto: Malversation of Public Funds under Article
217 of the Revised Penal Code (RPC) (Criminal Case No. 2005-1047). Leila Ang, Rosalinda
Driz, Joey Ang, Anson Ang, and Vladimir Nieto: Violation of Section 3(e) of RA 3019 (Anti-
Graft and Corrupt Practices Act) (Criminal Case No. 2005-1048). The respondents were accused
of defrauding the Development Bank of the Philippines (DBP)-Lucena City Branch in the
amount of P4,840,884.00 On November 10, 2005, the OMB-Luzon filed three separate
Informations before the Regional Trial Court (RTC) of Lucena, Branch 53.

ISSUE:

Whether the Request for Admission under Rule 26 of the Rules of Court is applicable in
criminal proceedings.

RULING:

The Supreme Court reversed the Sandiganbayan's Decision and Resolution, declaring the
RTC's Joint Orders dated February 12, 2015, July 24, 2015, March 10, 2016, and September 5,
2016, as void. The Court held that Requests for Admission under Rule 26 of the Rules of Court
are not applicable in criminal proceedings. The Rules of Criminal Procedure do not provide for
such a mode of discovery. The consolidation of the criminal cases did not extend the effect of the
implied admissions in one case to the other cases. The consolidation was for joint trial purposes
only, not for the merger of evidence.
36
People v Siton
G.R. No. 169364, September 18, 2009

FACTS:

Siton and others were charged with vagrancy under Article 202(2) of the Revised Penal Code
(RPC). They filed motions to quash, arguing that the law was unconstitutional due to vagueness
and overbreadth, but the Municipal Trial Court (MTC) denied their motions, emphasizing that
the law was a valid exercise of police power aimed at protecting public welfare. The MTC also
noted that the accused had been under surveillance in an area known for vagrancy and
prostitution.
Seeking to overturn the ruling, Siton et al. filed a petition for certiorari and prohibition before the
Regional Trial Court (RTC), challenging the constitutionality of Article 202(2) on three grounds:
(1) its vague definition, (2) its arbitrary identification of violators, and (3) its alleged
discrimination against the poor and unemployed, violating the equal protection clause. The
Office of the Solicitor General (OSG) countered that the doctrines of overbreadth and vagueness
apply only to free speech cases and maintained that the law should be presumed valid. However,
the RTC ruled in favor of Siton et al., declaring Article 202(2) unconstitutional for being vague
and violating the equal protection clause.

ISSUE:

Whether or not Art. 202 (2) is unconstitutional.

HELD:

CONSTITUTIONAL. The power to define crimes and prescribe penalties is a legislative

function inherent in the state's police power, which is broad and covers public health, safety,
morals, and welfare. Congress must clearly define crimes to inform citizens of prohibited acts, as
required by the void-for-vagueness doctrine, which ensures laws are not so ambiguous that they
lead to arbitrary enforcement. The Papachristou doctrine, which invalidates vague laws for
failing to provide fair notice or encouraging discriminatory enforcement, does not apply in the
Philippines due to the principle that ignorance of the law excuses no one. Article 202(2) does not
violate the equal protection clause, as it punishes conduct that threatens public order, not a
person’s social status. Vagrancy is considered a crime that disrupts societal norms and public
peace. The law should be presumed valid and constitutional, as courts must exercise caution in
striking down statutes and uphold the separation of powers, recognizing that laws enacted by
Congress and the President are presumed to comply with the Constitution.
37 JAVIER vs. SANDIGANBAYAN, FIRST DIVISION
G.R. Nos. 147026-27 | September 11, 2009

Facts:

Republic Act No. 8047, or the Book Publishing Industry Development Act, was enacted in 1995
to support the continuous growth of the book publishing industry by encouraging private sector
participation, ensuring an ample supply of affordable and high-quality books for local and
international markets. To implement this, the National Book Development Board (NBDB) was
established under the Office of the President. Petitioner Javier, appointed as a private sector
representative on the Board, was tasked with attending book fairs to foster international
publishing ties. She was authorized to travel to Madrid, Spain, on September 29, 1997, with
P139,199.00 in funds, but failed to attend the event and did not return the money. Consequently,
the Ombudsman charged her with corrupt practices, leading to a malversation of public funds
case before the Sandiganbayan. Javier sought to dismiss the case through a Motion to Quash,
arguing that the Sandiganbayan lacked jurisdiction since she was not a public official with a
Salary Grade 27 or higher, maintaining that she was merely a private sector representative on the
Board.

Issue: Is Petitioner Javier subject to the sanctions of the Ombudsman and/or Sandiganbayan even
if she was merely a private sector representative to the Governing Board?

Held:
YES. The Governing Board is the government agency mandated to develop and support
Philippine book publishing industry. It is a statutory government agency (i.e. an agency created
by law). It partakes public functions, thus whoever is appointed to be part of it is considered a
public officer.

Even if the petitioner was a private sector representative, she was nevertheless given “sovereign
function” of the government to achieve the goal of RA 8047 (“Book Publishing Industry
Development Act”), which is to ensure full development of the book publishing industry of the
State.
38. De Vera vs Pelayo (2000)
G.R. No. 137354 Jul 6, 2000

Facts:
De Vera faced an ejectment complaint before the Metropolitan Trial Court (MTC) and sought to
stop the proceedings by filing a special civil action for certiorari, prohibition, and mandamus
with the Regional Trial Court (RTC), which was denied, as was his subsequent appeal to the
Supreme Court (SC). He then lodged a complaint with the Office of the Ombudsman against
Judge Pelayo, accusing him of violating Articles 206 and 207 of the Revised Penal Code (RPC)
and Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) for allegedly issuing an
unjust interlocutory order and causing malicious delay in justice. After review, an Associate
Graft Investigation Officer recommended closing and terminating the complaint, referring it to
the Ombudsman, which then forwarded the case to the Court Administrator of the Supreme
Court and later denied De Vera’s motion for reconsideration. De Vera insisted that since his
complaint was a criminal charge against a judge, the Ombudsman, not the Supreme Court, had
jurisdiction to resolve the matter.

ISSUE: whether or not the Ombudsman has jurisdiction to entertain criminal charges filed
against a judge of the regional trial court in connection with his handling of cases before the
court.
HELD: NO
The referral of the case to the Supreme Court is correct. The Court applied the the ruling in In
Re: Joaquin Borromeo, wherein it laid down the rule, that before a civil or criminal action
against a judge can be entertained, there must first be "a final and authoritative judicial
declaration" that the decision or order in question is indeed "unjust." The pronouncement may
result from either:
(a) an action of certiorari or prohibition in a higher court impugning the validity of the
judgment; or
 (b) an administrative proceeding in the Supreme Court against the judge precisely for
promulgating an unjust judgment or order.
That no other entity or official of the Government, not the prosecution or investigation service of
any other branch, not any functionary thereof, has competence to review a judicial order or
decision -- whether final and executory or not -- and pronounce it erroneous so as to lay the basis
for a criminal or administrative complaint for rendering an unjust judgment or order. That
prerogative belongs to the courts alone.

39 Magno vs. Commission on Elections

G.R. No. 147904 Oct 4, 2002

Facts:

Carlos Montes petitioned for the disqualification of Nestor Magno from running as mayor
of San Isidro, Nueva Ecija, in the May 14, 2001 elections. Montes argued that Magno was
ineligible due to his previous conviction by the Sandiganbayan for four counts of direct bribery,
a crime involving moral turpitude.
The Commission on Elections (COMELEC) granted the petition, citing Section 12 of the
Omnibus Election Code, which disqualifies individuals convicted of crimes involving moral
turpitude unless they have received a pardon or amnesty. COMELEC ruled that since Magno
completed his sentence on March 5, 1998, his five-year disqualification would only lapse on
March 5, 2003, making him ineligible for the 2001 elections. COMELEC denied Magno’s
motion for reconsideration.
Magno contended that direct bribery is not a crime of moral turpitude and argued that the
applicable law should be Section 40 of the Local Government Code of 1991 (RA 7160), which
imposes a two-year disqualification after serving a sentence. Since he completed his sentence on
March 5, 1998, Magno claimed his disqualification ended on March 5, 2000, making him
eligible to run in 2001.

Issue: Whether or not direct bribery is a crime involving moral turpitude

Held:

Moral turpitude refers to acts of baseness, depravity, or dishonesty that violate societal
standards of right and duty. However, not all crimes involve moral turpitude—it depends on the
circumstances of the offense.
In this case, by applying for probation, Magno effectively admitted to the elements of direct
bribery, which include being a public officer, accepting a gift or promise, and doing or refraining
from an official act in exchange for personal gain. The third element, where the offender unjustly
acts or neglects official duties for a bribe, demonstrates moral turpitude, as it reflects deliberate
dishonesty and betrayal of public trust.
Furthermore, abusing one’s official position for personal benefit contradicts principles of justice,
honesty, and good morals. Given these factors, direct bribery is considered a crime involving
moral turpitude.

40 ABDULLA VS. PEOPLE

G.R. No.150129 APRIL 6,2005

FACTS:

Petitioners were working for the Sulu State College and were tasked and accountable for the public
funds under their administration. They conspired and confederated with Mahmud Darkis to apply for the
payment of wages of casuals to the tune of 40 000 pesos which was intended for the salary differentials of
the secondary school teachers of the school. Both Darkis and Aguil were acquitted, but Abdulla was
charged with technical malversation.

ISSUE:

Whether or not the petitioner is guilty of the crime of illegal use of public funds

HELD:
No, Criminal intent is absent.

Article 220 of the RPC provides for the elements:

1.The offender is a public officer.

2.That there is a public fund under his administration.
3.That such public fund or property has been appropriated by law nor ordinance
4.That he applies the same to a public use other than that for which such
Fund or property has been approriated by law or ordinance.

*Elements 2 and 3 are absent

The fund is from the “lump sum appropriation” of RA 6688

41 ALFREDO L. AZARCON VS SANDIGANBAYAN, PEOPLE OF THE PHILIPPINES
and JOSE C. BATAUSA
G.R. No. 116033 February 26, 1997

Facts:

Alfredo Azarcon, owner of an earth-moving business contracted by the Paper Industries

Corporation of the Philippines (PICOP), became involved in a legal dispute when the Bureau of
Internal Revenue (BIR) issued a Warrant of Distraint against his subcontractor, Jaime Ancla, a
delinquent taxpayer. The BIR also issued a Warrant of Garnishment to Azarcon, ordering him to
surrender any property belonging to Ancla in his possession.
Azarcon signed a receipt acknowledging custody of an Isuzu dump truck on behalf of the
BIR, assuming responsibility for its safekeeping. However, he later informed the BIR that Ancla
had removed the truck from his custody. It was discovered that Ancla had been renting out the
truck to a contractor named Oscar Cueva. As a result, the BIR filed a complaint against both
Azarcon and Ancla, leading to charges of malversation of public funds or property before the
Sandiganbayan.
Azarcon requested a reinvestigation, arguing that he had not been present during the
preliminary investigation and was not a public officer, making his malversation charge
questionable. Despite this, the Sandiganbayan found him guilty beyond a reasonable doubt and
sentenced him to imprisonment ranging from 10 years and 1 day to 17 years, 4 months, and 1
day.

Issue:

WON the Sandiganbayan have jurisdiction over a private individual who is charged with
malversation of public funds as a principal after the said individual had been designated by the
Bureau of Internal Revenue as a custodian of distrained property’

Ruling:
None. We find no provision in the NIRC constituting such a person a public officer by reason of
such requirement. The BIR's power authorizing a private individual to act as a depositary cannot
be stretched to include the power to appoint him as a public officer.

The language of the foregoing provision is clear. A private individual who has in his charge any
of the public funds or property enumerated therein and commits any of the acts defined in any of
the provisions of Chapter Four, Title Seven of the RPC, should likewise be penalized with the
same penalty meted to erring public officers. Nowhere in this provision is it expressed or implied
that a private individual falling under said Article 222 is to be deemed a public officer.

Rodillas Vs. Sandiganbayan

GR No. L-58652 May 20, 1988

Facts:

Rodillas, as a policeman, charged to deliver and return a detention

prisoner. Petitioner allows and permits the detention prisoner to have snack
and enter the comfort room without first ascertaining whether the said
comfort room is safe and without any egress by which the said detention
prisoner could escape. Thus, the detention prisoner enabled to escape thru
the window inside the comfort room and ran away from the custody of the
said accused.

Issue:
Whether or not the petitioner violated the crime of Infidelity in the
Custody of Prisoner thru Negligence.

Ruling:
Yes. The elements of the crime are: a) that the offender is a public
officer; b) that he is charged with the conveyance or custody of a prisoner,
either detention prisoner or prisoner by final judgment; and c) that such
prisoner escapes through his negligence.
There is no question that the petitioner is a public officer. Neither is
there any dispute as to the fact that he was charged with the custody of a
prisoner. It is evident from the records that the petitioner acted negligently
and beyond the scope of his authority when he permitted his charge to
create the situation which led to her escape.
As a police officer who was charged with the duty to return the
prisoner directly to jail, the deviation from his duty was clearly a violation of
the regulations.

43 People v. Baring Jr.

G.R. No. 137933 | 6 SCRA 219 | January 28, 2002

Facts:
Valentin Baring, Jr. was indicted for the statutory rape of a seven-year-old girl, Jennifer
Donayre, in Dasmariñas, Cavite. The information alleged that Baring, taking advantage of his
superior strength and the victim's age, had carnal knowledge of her against her will on several
occasions prior to August 2, 1997. Jennifer, who had been living with her grandmother and
referred to Baring as "Papa," reported the abuse to her grandmother, who subsequently filed a
complaint with the National Bureau of Investigation. A medical examination revealed that
Jennifer was in a non-virgin state, with physical findings consistent with sexual abuse.
During the trial, Jennifer provided clear and detailed testimony about the abuse, stating
that Baring had repeatedly touched her private parts and raped her. Baring denied the allegations,
claiming that Jennifer was not living with them during the alleged incidents and asserting that he
was framed for the crime. The Regional Trial Court found Baring guilty of rape and sentenced
him to death by lethal injection, along with monetary damages to the victim.
Baring appealed the conviction.

Issues:
 1. Whether the trial court's decision provided sufficient factual and legal basis for the
conviction.
2. Whether the absence of the examining physician as a witness deprived the accused of his
right to confront witnesses against him.

Ruling:
The Supreme Court upheld Baring’s conviction but reduced his sentence from death to reclusion
perpetua. It ruled that while the trial court’s decision was brief, it sufficiently established the
facts and legal basis for conviction. The Court emphasized that a medical examination is not
required for a rape conviction if the victim’s testimony is credible.
It also found that Baring’s counsel had waived the right to cross-examine the examining
physician, nullifying the claim of being denied the right to confront witnesses. Additionally, the
Court ruled that the delay in reporting the crime did not undermine the victim’s credibility, given
her young age and the circumstances of the abuse.
Regarding sentencing, the Court clarified that the death penalty under the Revised Penal Code
for qualified rape did not apply because Baring was not the common-law spouse of the victim’s
mother. As a result, the proper sentence was reclusion perpetua.

44 PEOPLE vs. PAYCANA, JR.,

G.R. No. 179035 April 16, 2008

FACTS:
Accused while armed with a kitchen knife and with intent to kill, assaulted and stabbed his wife
for several times, the latter being 7 months old pregnant, fatally hitting the different parts of her
body died with her child. The accused claimed self-defense, stating that his wife attacked him
first with a knife following an argument over a suspected infidelity. However, the trial court
found him guilty on April 14, 2005. His automatic appeal was denied by the Court of Appeals on
May 30, 2007. He then filed another appeal on June 14, 2007.

ISSUE:
WON that the trial court erred in not appreciating the justifying circumstance of self-defense in
his favor.
WON the accused committed unintentional abortion

HELD:
1. The Supreme Court ruled that the accused did not act in self-defense. Self-defense is a factual
issue best determined by the trial court, which had no reason to overturn its findings. The burden
of proving self-defense rests on the accused, who must provide clear and convincing evidence.
However, the accused's claim was contradicted by eyewitness testimony from his daughter,
Angelina, and father-in-law, Tito, as well as medical findings. Angelina testified that her father
strangled and stabbed her mother despite her pleas to stop. The trial court, upheld by the Court of
Appeals, properly convicted the accused of parricide with unintentional abortion for killing
his seven-month-pregnant wife.
2. Yes. Governed by Article 48, because by a single act, that the stabbing of his wife, appellant
committed a grave felony of parricide as well as the less grave felony of unintentional abortion.
A complex crime is committed when a single act constitutes two or more grave or less grave
felonies

45 PEOPLE vs. ABARCA

G.R. No. 74433 September 14, 1987

Facts:

On July 15, 1984 at around 6:00 PM, accused Francisco Abarca went home and found his
wife, Jenny, and Khingsley Koh in the act of sexual intercourse. When the wife and Koh noticed
the accused, the wife pushed her paramour who got his revolver. The accused who was then
peeping above the built-in cabinet in their room jumped and ranaway. The accused went to look
for a firearm at Tacloban City. At around 6:30 p.m. he got an M-16 rifle and went back to his
house. He was not able to find his wife and Koh there. He proceeded to the hangout of Kingsley
Koh. The accused found Koh playing mah-jong and fired at him three times with his rifle. Koh
was hit and died instantaneously. Arnold and Lina Amparado who were occupying the adjacent
room were also hit by the shots fired by the accused. Arnold and Lina Amparado were rushed to
the hospital and were rendered timely medical assistance that prevented their deaths. In line with
this, the Regional Trial Court of Palo, Leyte, sentenced the accused-appellant Francisco Abarca
to death for the complex crime of murder with double frustrated murder. He filed a statement
informing wishing to continue with the case by way of an appeal.

Legal Issues:
 1. Whether or not Article 247 of the Revised Penal Code defining death inflicted under
exceptional circumstances can be applied in the instant case dissolving the criminal
liability of the accused for the murder of the deceased.
2. Whether or not the accused is liable for frustrated murder for the injuries suffered by the
Amparados.

Ruling:

The case at bar requires distinctions. Here, the accused-appellant was not committing
murder when he discharged his rifle upon the deceased. Inflicting death under exceptional
circumstances is not murder. It cannot therefore hold the appellant liable for frustrated murder
for the injuries suffered by the Amparados. For the separate injuries suffered by the Amparado
spouses, we therefore impose upon the accused-appellant arresto mayor (in its medium and
maximum periods) in its maximum period, arresto to being the graver penalty (than destierro).

The decision appealed from is hereby MODIFIED. The accused-appellant is sentenced to

four months and 21 days to six months of arresto mayor. The period within which he has been in
confinement shall be credited in the service of these penalties. He is furthermore ordered to
indemnify Arnold and Lina Amparado in the sum of P16,000.00 as and for hospitalization
expense and the sum of P1,500.00 as and for Arnold Amparado's loss of earning capacity. No
special pronouncement as to costs.
46 THE PEOPLE vs. ARAQUEL
G.R. No. L-12629 December 9, 1959

FACTS:

The acting chief of police of Narvacan, Ilocos Sur, filed with the Justice of the Peace Court a
complaint for homicide against Alfredo Araquel accusing him of having hacked and killed
Alberto Pagadian with a bolo. While said complaint, was still pending in the justice of the peace
court, the chief moved for the amendment thereof, alleging that upon reinvestigation of the facts
he found that the crime committed by the accused was not homicide as charged in the original
complaint but that of homicide under exceptional circumstances as provided for in article 247 of
the Revised Penal Code. Finding the motion to be well taken, the justice of the peace court,
allowed the filing of the amended complaint. The accused was arraigned under the amended
complaint and pleaded “guilty” on the offense. During the service of the sentence by the accused,
the acting Provincial Fiscal of Ilocos Sur was informed of the case through the Department of
Justice to which the private prosecutor had lodged a complaint. Said provincial fiscal then filed
with Court of First Instance an information against the accused Araquel charging him with
homicide as defined under Article 249 of the Revised Penal Code for the killing Alberto
Pagadian. The accused moved to quash the information on the ground of double jeopardy. The
fiscal opposed the motion, but the trial court sustained the plea of double jeopardy and dismissed
the information.

ISSUE: Whether the trial court erred in sustaining the plea of double jeopardy
RULING:

The Supreme Court ruled that the accused’s plea of double jeopardy was wrongly upheld by the
lower court. For double jeopardy to apply, the accused must have been tried before a court of
competent jurisdiction. The lower court mistakenly held that the Justice of the Peace Court had
jurisdiction based on the penalty of destierro (exile). However, Article 247 of the Revised Penal
Code does not define a separate crime but merely provides a privilege or benefit for certain
killings. Since the Justice of the Peace Court lacked jurisdiction over the case, the accused was
not legally placed in jeopardy, and the plea of double jeopardy was invalid.

US VS. VARGAS

G.R. No. 1053 | May 7, 1903

FACTS

Simeon Alberto on May 20, 1902, was attacked and severely wounded. To the persons
who went to his assistance he stated that the defendants had assaulted him. He said nothing of the
motive. He died the next day. There was no other evidence for the Government. Manalastas was
acquitted by the court. The defendant Vargas testified that, on returning to his house on the day
in question, he found Alberto lying with his (the defendant’s) wife; that he drew his bolo;
Alberto wife; that he drew his bolo; Alberto escaped through the window; that he, the defendant,
pursued him, overtook him, and killed him. There was evidence that the relations existing
between Alberto and the wife of the defendant had been the subject of common talk in the barrio.

ISSUES

Whether the judge erred in sentencing the defendant to eight years of prision mayor
RULING

The court agrees as to the facts, but not as to the application of said article 423. This
article fixes the penalty of destierro when the husband kills the offender “in the act.” In this case
the discovery, the escape, the pursuit, and the killing were all parts of one continuous act. The
judgment of the court is reversed, and the defendant Vargas is condemned to the penalty of
destierro for the term of two years four months and one day, to pay the heirs of the deceased
1,000 pesos, and in case of insolvency to subsidiary destroy for a term which cannot exceed one-
third of the above penalty, he being prohibited from entering in a radius of 25 kilometers from
the barrio of Santa Monica, in the pueblo of Floridablanca, in the Province of Pampanga, during
the term aforesaid, with costs to the Appellant.

PEOPLE VS. SANTOS

G.R. NO. L-38512 | NOVEMBER 16, 1979

FACTS

On July 22, 1973, at around 2:00 AM, Ernesto Garcia and his family were sleeping in
their house in Barrio Nagserialan, Camiling, Tarlac. His wife, Adelaida Banigued, was awake
weaving a mat. Shouts for help from the neighboring house of Dominador and Basilia Dancel
awakened the Garcias. They rushed out to assist. Myra Garcia, the victim, testified that upon
running outside, she saw her mother being hacked by the appellant, Reynaldo Santos, alias
"Kirkir," with a bolo Appellant straddled her, pressed the bolo against her neck, and threatened
to kill her if she screamed. Despite her struggles and screams, appellant consummated the sexual
act. Ernesto Garcia’s Actions. Appellant admitted to having carnal knowledge of Myrna but
claimed it was consensual. He alleged that his uncle, Dominador Dancel, ordered him to "take
advantage of Myrna’s womanhood" and threatened to kill him if he refused. Appellant claimed
that Myrna voluntarily accompanied him to the fields and consented to sexual intercourse.

ISSUE:

Whether the appellant employed force or intimidation to commit the rape.

RULING:

The Supreme Court affirmed the conviction of the appellant for the crime of rape but
modified the penalty from death to reclusion perpetua. The Court found that the appellant used
force and intimidation, as evidenced by the victim’s testimony, corroborated by her father and
the Barrio Captain. The Court rejected the appellant’s defense of consent, noting that the victim’s
age, the circumstances of the attack, and the presence of the bolo made her consent highly
improbable. The Court held that nocturnity and uninhabited place could not be considered
aggravating circumstances, as there was no evidence that the appellant deliberately sought the
cover of darkness or isolation.

49 PEOPLE VS. PUGAY

G.R. NO. L-74324 NOVEMBER 17, 1988

FACTS:
The incident occurred on May 19, 1982, at the town plaza of Rosario, Cavite, during a town
fiesta. Bayani Miranda, a 25-year-old with a mental disability. Fernando Pugay y Balcita and
Benjamin Samson y Magdalena. Pugay and Samson, along with their companions, were making
fun of Miranda by tickling him with a piece of wood. Pugay then poured gasoline on Miranda,
believing it to be water, and Samson set him on fire. Miranda tragically died as a result.

ISSUES:
Whether conspiracy present in this case to ensure that murder can be the crime

RULING:
No, the 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
must be proof as to the existence of a previous agreement to commit a crime. However, it is
sufficient if at the time of the commission of the crime, the accused has the same purpose and
were united and executed. In the case at bar, there was no animosity between Miranda and the
accused; to add that at the commission of the crime, the accused’s intent was purely coincidental
since he is under the influence of liquor at the commission of the crime. The court found both
Pugay and Samson guilty of murder.

PEOPLE VS. GUILLERMO

G.R. NO. 147786, JANUARY 20, 2004

FACTS:
The incident occurred on March 22, 1998, in Antipolo City, Rizal. Victor Francisco Keyser,
the owner and manager of Keyser Plastic Manufacturing Corp. The accused Eric Guillermo
Garcia, armed with a piece of wood and a saw, attacked Keyser inside the premises of Keyser
Plastics. He hit Keyser with the piece of wood and then cut him into pieces using the saw,
inflicting mortal injuries that led to Keyser's death.

ISSUES:
Whether Guillermo was criminally liable for the murder of Keyser.

RULING:
The Supreme Court affirmed the guilt of Guillermo but modified the sentence from death to
reclusion perpetua. The Court found several points for legal consideration; Guillermo’s
confession during police custody was deemed inadmissible due to violation of constitutional
rights during custodial interrogation. Admissions made to the security guard Campos and media
interviews were considered voluntary and part of the res gestae, as they were spontaneous and
not elicited through interrogation by authorities. Treachery as a qualifying circumstance was not
sufficiently proven due to lack of eyewitness testimony on the manner of the attack. However,
the act of dismembering the victim’s body was considered as outraging or scoffing at the corpse,
qualifying the crime as murder.