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People vs.

While Alfredo, Cayetano, Romualdo, and Manuel were eating and drinking, and while the music was playing,
Romualdo asked if he could dance with Alfredos daughter. Alfredo demurred as his daughter didnt known
how to dance. Cayetano insisted that Romualdo dance with Alfredos daughter, anyway, Cayetano
reasoned, my nephew is already thru with your daughter and someday, well be in-laws. Alfredo stood up in
anger as he threw a glass of beer. Likewise, Cayetano stood up and the two were about to fight when their
companions prevented them. When Cayetano was about to leave, he said Time will come that well meet.
The eating and drinking continued until Romualdo asked to leave. Alfredo insisted on accompanying him, and
so it was. As they were travelling, Manuel asked to be dropped at their house as his jealous wife might be
worrying. Alfredo refused, and made Manuel agree that instead, the former himself would inform Manuels
When a certain Hugo saw that Alfredo is coming, he warned Cayetano, but the latter said We are not
enemies. However, Alfredo shot Cayetano from behind.
ISSUE: Whether or not mitigating circumstance of having acted in vindication of a grave offense may be
availed of?
RULING: Yes. Alfredo was embarrassed by the utterance of these words. He sought to vindicate the honor of
his family and appease his self respect when he killed the deceased. In fact, Alfredo and Cayetano would
have fought each other had not their companions separated them. Thus, Alfredo acted in proximate
vindication of a grave offense committed by Cayetano against the honor if his daughter.
People vs. Ignas
Ignas was married to Wilma. Wilma was however an unfaithful wife, for he was having an affair with
Nemensio. Two nights before Wilma have left for Taiwan, together with Nemensio, and Romenda, they stayed
at Dangwa Inn. Nemensio and Wilma shared a room.
When Wilma was already at Taiwan, Romenda received a letter from Wilma, instructing the former to reveal
the extra-marital affair to Juan. Upon the information, Juan said I will kill Nemesio.
After two weeks, Juan killed Nemesio.
ISSUE: Whether or not there is a mitigating circumstance of vindication of a grave offense?
RULING: None. The word immediate or proxima in Spanish, allows a lapse of time between the grave
offense and the actual vindication. However, the lapse of two weeks between the discovery of the wifes
infidelity and killing could no longer be considered proximate. The passage of a fortnight is more than
sufficient time for appellant to have recovered his composure and assuaged the unease in his mind. The
established rule is that there can be no immediate vindication of a grave offense when the accused had
sufficient time to recover his serenity.
People vs Ventura
FACTS: Felix Ventura and Johanna were husband and wife.
Arante Flores went to see his uncle, Felix. The two conversed and Arante confirmed that Johanna was having
an illicit affair with Jaime. He knew this for he was working at the meat shop of the Bocateja spouses.
Eventually, the two decided to confront Jaime. After five (5) days, they went to Bocatejas place.
It was about 2 A.M., when Jaime Bocateja was awakened by the stealthy entrance of Felix and Arante into his
house. Felix pointed a gun to Jaime and announced a hold-up. Aileen was awakened as well, and began
shouting for her husband was in danger. Arante stabbed Aileen.
Aileen died. Jaime remained in the hospital for six days.
ISSUE: Whether or not the mitigating circumstance of passion or obfuscation is present?
RULING: No. Jealousy may give rise to passion or obfuscation. However, for this to qualify as mitigating
circumstance, the time between the act which produced the obfuscation and the crime must not be sufficient
for the accused to recover his normal equanimity and composure.

People vs. Alanguilang

FACTS: Juan Alanguilang, prompted with jealousy, hit Aurelia Brion, hiw wife, with a piece of firewood on the
arm and on the abdomen until he finally caused her death.
ISSUES: Whether or not the mitigating circumstance of passion or obfuscation is present?
RULING: No. In order for the circumstance of obfuscation can be considered, it is necessary to establish the
existence of an act both unlawful and sufficient to produce such a condition of mind; and that said act which
produced the obfuscation was not far removed from the commission of the crime by a considerable length of
time, during which the perpetrator might recover his equanimity.
People vs. Lupera
FACTS: Rufino had always been in the company of the Japanese soldiers. He also helped them arrest and tie
Filipinos during the war. Consequently, he was charged of treason.
In his defense, he could have not possibly help tying his fellow citizens because his left leg is lame that he
can bend his right arm to theextent of only 25 degrees and he can raise his left arm only up to the level of his
ISSUE:Whether or not there is a mitigating circumstance of physical defect suffered by the offender?
RULING: The old age and physical infirmities of the accused while they might have ordinarily limited his
sphere of action certainly did not immobilize him and not prevent him from going wherever he pleased and if
we are to believe his claim he was even able to come and live alone in Manila Frequenting his claim he parts
of the city in the pursuit of his tailoring work. This only shows that his physical infirmities did not restrict his
freedom of movement.
People vs. Nazario
FACTS: Anacleto robbed an inhabited house. As a defense, he claimed through his counsel that he is deaf and
dumb. He does not even know the import of his plea of guilt.
ISSUE: Whether or not there is a mitigating circumstance?
RULING: Yes. He is entitled to mitigating circumstance of being deaf and dumb.
People vs. de la Pea
FACTS: Carlos took away ten pairs of socks from Toyo Bazar. He was prosecuted and convicted of the crime of
theft in municipal court of Manila. CFI affirmed the decision.
He averred that he voluntary confessed before CFI Manila, thus he should be entitled to a lower penalty.
ISSUE: Whether or not there is a mitigating circumstance of voluntary confession?
RULING: There is none. The confession must be made in open court at the first opportunity. In this case, the
accused only made the confession when the case was already in CFI Manila, which was acting then as an
appellate court, and not the court with original jurisdiction over the case.
People vs. Oandasan
FACTS: Mariano Oandasan saw Quirino Duldulao chasing the formers son, so he asked why he was doing so.
In response, Quirino hit Mariano with a wooden club on the left shoulder. Mariano drew a sharp-pointed knife,
but immediately, Quirino hit Mariano once again on the head. In the end, Mariano stabbed Quirino and died.
The charge of homicide was lodged with Municipal Court. At the preliminary investigation, Mariano pleaded
not guilty. The case was elevated to CFI for trial [as the crime of homicide is within the original jurisdiction
of CFI]. This time, he pleaded guilty before the CFI during arraignment.

ISSUES: Whether or not there is a mitigating circumstance of plea of not guilty?

Whether or not there is incomplete self-defense?
RULING Yes. The accused entered a plea of guilty when the case was heard at the first opportunity by a
competent court. Although he simply changed his plea when it was being heard by the CFI, the CFI in this
case was not acting as an appellate court, but actually had the original jurisdiction over the case. Thus, the
first opportunity that the accused may enter a plea of guilt before a competent court was during trial before
Yes. What was lacking was only reasonable necessity of the means employed to prevent unlawful aggression.
There is unlawful aggression when Duldulao hit the accused. Thus, there would have been a complete selfdefense, had not the means employed been unreasonable.
People vs. Antonio Bueza
FACTS: One night, when Nilda was cooking their supper, and when her husband Juanito and their small child
was asleep, Antonio Bueza and Rodolfo Solis, armed with bolo and powder, came and tried to drag Nilda.
Nilda refused so the accused threw stones at the house. Juanito got awake, and tried to defend them, but was
killed by the accused.
During the investigation by the police officer, the accused were informed of their constitutional right and the
accused admitted the killing. They said that Juanito was chasing them with a bow and arrow so they hid.
However, after hiding, Juanito was around and a violent encounter transpired, which led to the death of
Juanito. The custodial investigation was done without a present independent and competent counsel.
ISSUE: Whether or not the confession has a probative value?
RULING: No. The accused, in an extrajudicial confession, in a custodial investigation in this case, when
making a confession, should be assisted by a competent and independent counsel, as provided for in the
1973 constitution
People vs. Comendador
FACTS: Comendador confessed that he robbed and killed Jungie Zaragosa because he needed money. Such
confession was made before the Toledo City Police Department at the presence of Atty. Ramolete. Prior to the
confession, he was made to know his constitutional right.
He was convicted by the CFI. The defendant now seeks to take his pleas as a plea of not guilty, because he
claims that his plea was conditional. In other words, his plea would be one of guilty if only to reduce his
penalty, but not if only to avoid his conviction.
ISSUE: Whether or not there is such thing as conditional plea?
RULING: There is no such thing. A plea of guilty must be made unconditionally. Its effect would be admitting
not only the crime but as well as the attending circumstances.
People vs. Ong
FACTS: Henry Chua and his companions went to the office of Benjamin Ong. In a loud voice, with angry
gestures, and in the presence of his subordinates and fellow employees, Henry Chua demanded payment,
and threatened bodily harm to him and his family.
One night, falling into despair and loosing all hope, Benjamin tried to ask Henry to give him more time, but
Henry refused to do so. Instead, the relentless Henry uttered contempt and disdain of Benjamin. The poor
Benjamin became so disoriented that the next day, he killed Henry.
ISSUES: Whether or not plea of guilty is still considered mitigating although accused disputes some of the
aggravating circumstances alleged in the information?
Whether or not there is passion and obfuscation?

RULING: Yes. Although the confession was qualified and introduction of evidence became necessary, the
qualification must not deny the defendants guilt. It is not the fault of the defendant that an aggravating
circumstance was erroneously alleged in the information, thus, he should not be deprived of the benefit of
plea of guilt if in such case, he had to present evidence to counteract such unfounded allegations of
aggravating circumstances.
Yes. Benjamin was discredited and degraded in front of his brother-in-law. He was also pressured to produce
the money demanded by Henry. Consequently, he became depressed. Furthermore, when he asked Henry to
give him more time, Henry refused to do so. It is not normal for any person under such circumstances to be
happy. Thus, when Benjamin committed the crime, he was driven by passion.
People vs. Saligan
FACTS: Gomez Saligan was convicted for Rape with Homicide. During arraignment, information was merely
read to the appellant whereupon he pleaded guilty. The trial court did not make sure that appellant fully
understood the nature of the grievous charge by law before it is imposed.
ISSUE: Whether or not the confession is admissible?
RULING: No. An unidentified extrajudicial confession is no more admissible than improperly admitted plea of
guilty. Judges are duty-bound to be extra solicitous in seeing to it that when an accused pleads guilty, he
understands fully the meaning of his plea and the import of an inevitable conviction. Because, material
averments in the information are couched in so technical a language that the ordinary layman may not fully
comprehend their meaning. The case was remanded to court a quo for new arraignment and further
People vs. Abrea
FACTS: During arraignment, Alberto entered the plea of guilty. The trial court asked him if he understands the
meaning of his plea of guilt. Moreover, he is informed that by such plea to the amended information, he may
suffer a maximum penalty of death. Lastly, the court informed him that he can still be allowed to withdraw his
previous plea of guilty to one of not guilty if that be his desire. However, he did not change his said plea, but
hastened to ask the Court that he be accorded leniency in the imposition of the penalty.
ISSUE: Whether or not admission of material allegations in the information includes qualifying and/or
aggravating circumstances?
RULING: No. The prosecution still has the burden of proving whatever qualifying or aggravating circumstances
the case may have, apart from the plea of guilt. This prevents miscarriage of justice because of false
confessions. Therefore, the prosecution has to present evidence to substantiate the allegations in the
information and thus guard against improvident admissions of guilt.
People vs. Apduhan
FACTS: One night, the accused, armed with unlicensed firearms, daggers, and other deadly weapons, entered
the house of Honorato and Antonia, and killed Geronimo Miano and Norberto Aton who happened to be in the
said place that time.
ISSUES: Whether or not there is mitigating circumstance of intoxication?
Whether or not the prosecution had to prove the aggravating circumstance when there is an unqualified plea
of guilty?
RULING: None. Intoxication was not competently proven where the only evidence was that the defendant took
young coconuts before they committed the crime. There is no mention about taking of any liquor, nor any
evidence to counteract the alleged intoxication.
On the part of the accused, he was not able to prove the presence of this mitigating circumstance.
No. An unqualified plea constitutes an admission of all the material facts alleged in the information, including
the aggravating circumstances therein recited.

People vs. Macbul

FACTS: Macbul stole two sacks of papers valued at P 10 belonging to the Provincial Government of Sulu.
ISSUE: Whether or not extreme poverty and necessity is a mitigating circumstance?
RULING: Yes. Such circumstance is analogous to other mitigating circumstances, and under the purview of
Art. 13 par. 10 of the Revised Penal Code.
People vs. Monaga
FACTS: Herminio and Marina were tenants of Juanita. Juanita told the spouses to vacate her land and the
house built upon it in consideration of P800. Herminio refused, unless she gives P3000. Jesus, brother of
Juanita, used force and intimidation to drive away the spouses from the house. However, they continued to
use the land.
Benhur, also a tenant, lost his female carabao. He asked Hermino about it, and the latter responded that they
would get the carabao if they pay him P50. The next morning, they found the carabao dead. Herminio
admitted that he took the carabao but in a jest for he was drunk at that time.
Jesus, Benhur, and others, ambushed and killed Herminio.
ISSUE: Whether or not there is mitigating circumstance?
RULING: Yes. Such circumstance is analogous to vindication of a grave offense. It is not exactly a
circumstance of vindication of a grave offense, because in this case, it was the property of the appellant that
was taken. The deceased took away the carabao of the appellant and held it for ransom. He failed to fulfill his
promise to pay its value after the carabao had died.
People vs. Dy Pol
FACTS: Dy Pol falsified a public document, by pretending to be Chua We before a notary public for the
purpose of selling the commercial establishment of the latter to the former.
ISSUE: Whether or not lack of irreparable material damage caused to the offended party is a mitigating
RULING: No. It is not recognized in the Revised Penal Code, nor similar or analogous to those expressly
People vs. Salazar
FACTS: Salazar had a common-law wife, Maxima Pacho. Salazar has a suspicion that his wife was having a
relation with Fortunato Nares, husband of Romana. He even believed that the child his wife was bearing was
the result of such illicit relation.
One day, he invited his wife to gather nipa for the repair of their house. However, Romana arrived and invited
Maxima to accompany her to her house to get palay. Maxima chose to go with Romana. Salazar got angry.
Salazar killed several persons.
He entered a plea of guilty. However, the accused appealed and averred that his plea did not extend to the
admission of the correctness of the qualification of his acts as expressed by the prosecution in its information,
particularly the alleged evident premeditation and treachery.
ISSUE: Whether or not the plea of guilty is enough to convict the accused?
RULING: Yes. A plea of guilty is an admission of all the material facts alleged in the information. A plea of
guilty when formally entered on arraignment is sufficient to sustain conviction of the offense charged without
the introduction of further evidence, upon the theory that the defendant himself has supplied the necessary
proof by his plea of guilty.