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PEOPLE v. RENEGADO
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PEOPLE v. RENEGADO
May 31, 1974 (G.R. No. L-27031)
PARTIES:
plaintiff-appellee: THE PEOPLE OF THE PHILIPPINES
accused-appellant: LORETO RENEGADO y SENORA
FACTS:
Mamerto de Lira was a math teacher in Tiburcio Tancinco Memorial Vocational School which is
run by the national government. Loreto Renegado was a clerk in the same school. De Lira
asked Renegado to type his exam questions but the latter refused. They had a small argument
which left the accused fuming with anger. The accused told several people that hell gonna kill
the deceased. They pacified him and told him the possible consequences that may happen.
After a few days, while the deceased was in the canteen sitting with his back towards the
accused, without warning the accused stabbed the deceased with a knife which later caused the
latters death. The counsel of the accused pleads for an acquittal on the ground that the
accused should be exempt from criminal liability because at the precise time he stabbed de Lira,
the accused lost his senses and he simply did not know what he was doing. His counsel
claimed that after Renegado was clubbed on the forehead, he suffered from head injury which
produced ill-effects.

ISSUE:
(1) WON the accused is exempt from criminal liability on the ground of insanity.
(2) What are the mitigating and aggravating circumstances present in the case.

HELD:
(1) No. Insanity exists when there is a complete deprivation of intelligence in committing act,
that is, the accused is deprived of reason, he acts without the least discernment because there
is a complete absence of the power to discern, or that there is a total deprivation of freedom of
the will, mere abnormality of the mental faculties will not exclude imputability. In the case at bar,
it just shows that Renegado is a man of violent temper who can be easily provoked to violence
for no valid reason at all. Thus in People vs. Cruz, this Court held that breaking glasses and
smashing dishes are simply demonstrations of an explosive temper and do not constitute clear
and satisfactory proof of insanity; they are indications of the passionate nature of the accused.
In the absence of proof that the defendant had lost his reason or became demented a few
moments prior to or during the perpetration of the crime, it is presumed that he was in a normal
condition of mind.
(2) The killing of Mamerto de Lira is qualified by evident premeditation. Here, the accused has
more or less sixty-four hours to ponder over his plan and listen to the advice of his co-
employees and of his own conscience, and such length of time was more than sufficient for him
to reflect on his intended revenge.
There is treachery committed. There is treachery where the victim who was not armed was
never in a position to defend himself or offer resistance, nor to present risk or danger to the
accused when assaulted. The accused killed the deceased while he was eating and his back
faced towards him.
There was an assault upon a person in authority. A teacher either of a public or of a duly
recognized private school is a person in authority.
The mitigating circumstance of voluntary surrender was offset by the aggravating circumstance
of treachery.

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LACSON VS POSADAS 72 SCRA 168 (1976)
Respondent Municipal Judge Ramon Posadas, of Talisay Negros Occidental,
is charged in a verifiedcomplaint by Salvador Lacson, Jr. with (a) ignoranceof the law,
(b) partiality, and (c) violation of theElection Code of 1971 which provides
that:Any person who has been refused registration orwhose name has been stricken out from th
epermanent list of voters may at any time exceptsixty (60) days before a regular election or
twenty-five (25) days before a special election, apply to
theproper court for an order directing the electionregistration board or the board of inspectors as
thecase may be, to include or reinstate his name in thepermanent list of voters, attaching to his
applicationfor inclusion the certificate of the Electronregistration board or the board of inspectors
regarding his case and proof of service of a copy of his application and of the notice of hearing
thereof upon a member of the said board (Emphasissupplied.)In the light of the statutory
purpose, the
seriousnessof respondent's failure to comply with therequirements of Section 136 of the elector
al lawbecomes evident. His good faith or lack of malice isof no avail, considering that in crimes
which are
mala prohibita
the act alone irrespective of its motives,constitutes the offense. It appears, however, that
onApril 8, 1974, the President of the Philippinespromulgated Presidential Decree No. 433, which
grants general amnesty under certain conditions
topublic school teachers, other government officialsand employees, members of the armed
forces of thePhilippines and other persons for violation of electionlaws and other related statutes
in connection withthe elections of 1965, 1967, 1969, 1971, and
theelection of delegates to the ConstitutionalConvention.WHEREFORE, respondent is hereby
admonished thathe should exercise greater care in the observance of the provisions of existing
laws in the discharge of his judicial duty, and warned that any subsequentmisconduct shall be
dealt with more severely.

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THEPEOPLE OF THEPHILIPPINES
(PLAINTIFF-APPELLEE)VS.DOMINGOURAL(ACCUSED-APPELLANT)L-30801
MARCH 271974J.AQUINO
APPEAL FROM A JUDGMENT OF THE CFI OF ZAMBOANGA DEL SUR
FACTS:
-Alberio went to the municipal building and saw Ural, a policeman inside the jail where he
wasboxing prisoner Napola (who was imprisoned for being drunk). When Napola fell to
the groundhe U kicked him and poured some liquid on N and then ignited Ns body.
-Dr. Luzonia Bakil who treated the victim, said that he sustained 2
nd
degree burns on the
arms,neck, left side of the face and one half of the body including the back. She also testified
thatwithout any medical intervention, the burns would have caused death
-Napola died on Aug 25 1966. Death certificate indicated burn as the cause of death
-During the trial, the prosecutors failed to present the detention prisoners who saw the burningof
Napola as witnesses as well as the wife of the deceased-
Nevertheless, Ural was convicted of murder, was sentenced to reclusion perpetua and
wasordered to pay for costs
ISSUE:
Whether the evidence of the prosecution was sufficient to prove his guilt beyond
reasonabledoubt