Set F

Manuel vs People
G.R. No. 165842, November 29, 2005
CALLEJO, SR., J.

Facts: The petitioner, Eduardo Manuel, was convicted for the crime of Bigamy in the RTC of Baguio. He
was first married to Rubylus Gaña on July 18, 1975, who were imprisoned for estafa in 1975 and was
never seen by him again. In 1996, he married Tina Gandalera without the latter’s knowledge of his first
marriage. When Gandalera found out, she filed a criminal case of bigamy against Manuel. The
petitioner’s defense is his good faith that his first marriage is invalid and he had acted without malicious
intent and that he did not know that he had to go to court to seek for the nullification of his first
marriage before marrying Gandalera.

Issue: WoN the petitioner’s contention of his good faith and lack of malicious intent is credible?

Held: No. The petitioner is presumed to have acted with malice or evil intent when he married the
complainant. As a general rule, mistake of fact or good faith of the accused is a valid defense in a
prosecution for a felony by dolo; such defense negates malice or criminal intent. However, ignorance of
the law is not an excuse because everyone is presumed to know the law. Where a spouse is absent for
the requisite period, the present spouse may contract a subsequent marriage only when he had a well-
founded belief that the absent spouse was already dead and after securing a judgment declaring the
presumptive death of the absent spouse to avoid being charged and convicted of bigamy.

Set H
People vs. Badriago
G.R. No. 183566, May 8, 2009
VELASCO, JR., J.

Facts: Oliver and Adrian Quinto were about to deliver a letter when they had an encounter with a
certain Bonifacio Badriago. According to Oliver, they were approached by the appellant and suddenly
hacked him with a long bolo on his lumbar area. He was able to shield himself thus suffering a hack
wound on his lower left arm. Oliver pushed Adrian off the tricycle so he could run away and call for help.
He lost consciousness and when he woke up at the Hospital, he was later informed that Adrian died. In
his defense, the appellant claimed that it was the brothers who chased him and insisted a fight. He
contend that it was Oliver who got off his pedicab and approached him with a knife, thus he grabbed his
bolo and strike at Oliver, injuring the latter’s left hand. The appellant denied the killing of Adrian.

Issue: WoN the Court of Appeals erred in not appreciating the mitigating circumstance of lack of
intention to commit so grave a wrong?

Held: No, The mitigating circumstance addresses itself to the intention of the offender at the particular
moment when the offender executes or commits the criminal act. Looking at the victims’ wounds,
however, the court cannot count the circumstance in accused-appellants favor. Adrian suffered a
hacking wound on his left forearm that caused near amputation, and another one on his lumbar area.
These wounds would have been fatal were it not for timely medical assistance. Oliver, on the other
hand, bore the brunt of the attack with eleven (11) different stab wounds, including one on the skull and
on the chest. The number, location, and nature of these stab wounds belie accused-appellants claim of
lack of intention to commit so grave a wrong against his victim.

Set I
Esquida vs. People
G.R. No. 170222, June 18, 2009
PERALTA, J.

Facts: On March 3, 1999, the common-law spouses Venancia Aliser and Gaudencio Quiniquito were
awakened by a voice coming from the outside of their house. When Gaudencio opened the door, the
petitioner, Edgar Equeda, suddenly stabbed and hit him on the chest. Venancia tried to run away but
was followed and was stabbed also by the petitioner. She then fell to the ground, but petitioner
continued stabbing her. Petitioner denied having committed the crime. The RTC finds the accused guilty
of the crime of frustrated homicide and was affirmed by the CA, thus this petition for review on
certiorari was filed with the SC. The defense anchored on alibi and denial and presented three
witnesses, who testified that the accused was out at sea fishing during the time of the crime.

Issue: WoN the trial court gravely erred in finding the petitioner guilty beyond reasonable doubt of
frustrated homicide and totally disregarding the latter’s defense?

Held: The Honorable Court did not disregard the defense of the accused petitioner in rendering its
decision. The presented alibis and denial by the defense are essentially weak against the positive
identifications made by the respondents. In this case, the defense of alibi failed. The positive
identification destroys the defense of alibi giving to such effect to be weak. A crime is frustrated when
the offender has performed all the acts of execution which should result in the consummation of the
crime but is not consummated by reason of the intervention of causes independent of the will of the
offender. In the case at bar, petitioner commenced the performance of his unlawful act by stabbing
Venancia at the back. After she was stabbed and fell on the ground, petitioner’s intent to consummate
the crime was shown by the fact that he continued stabbing Venancia even while she was on the
ground. However, the crime was not produced by reason of the timely medical intervention. Frustrated
Homicide is set aside by the SC and found the petitioner guilty beyond reasonable doubt of the crime of
Frustrated Murder
Set J
People vs. Sameniano
G.R. No. 183703, January 20, 2009
VELASCO, JR., J.

Facts: Roberto and Norming de los Santos were asleep in a nipa hut at an abaca plantation when three
intruders surrounded Roberto and then one of them, Jose Aguilar, hacked him with a bolo while another
man identified as Benedicto Felicidario, Jr. held Roberto’s hands. Norming rushed out to ask for help and
was chased by the appellant, Fernando Sameniano. All the accused were found guilty by the crime of
murder but plead not guilty.

Issue: WoN conspiracy attended the commission of the crime?

Held: Yes, the SC affirmed the findings of the RTC. The trial court noted the fact that the assailants came
and left the crime scene together. Accused-appellant and the two other accused arrived with flashlights
and bolos. The appellate court observed that while accused-appellant did not have a direct hand in
hacking the victim, his inaction or failure to prevent his companions from killing reveals his complicity to
the crime. Also, when Norming rushed out of the hut, accused-appellant chased him. These actions
reveal a unity of purpose present in conspiracy. The fact that accused-appellant did not inflict the fatal
blows does not negate conspiracy nor exculpate him from any liability. Where the acts of the accused
collectively and individually demonstrate the existence of a common design towards the
accomplishment of the same unlawful purpose, conspiracy is evident.