On December 16, 1907, accused Catalino Apostol and four other
individuals went to the hut of Pedro Tabilisima, Celestino Vergara
and Tranquilino Manipul to inquire after some carabaos had disappeared. They also believed that they had stolen the carabaos from them. When the above-mentioned inmates answered that they knew nothing about the matter, the accused and his companions ordered them to leave their house, but as the three men named above refused to do so, the accused Catalino Apostol, set fire to the hut and the same was burnt down. The trial court of Nueva Ecija sentenced the defendant to sixteen years and one day of cadena temporal, to the accessories of the law, to indemnify the value of the burnt hut in the sum of P1, and to pay the costs. An appeal has been taken to the Supreme Court and one of the defense claims of the defendant is their absence of proof of criminal intent.
ISSUE: Is the absence of proof of criminal intent a valid defense?
DECISION: No. Decision of the lower court is AFFIRMED.
RATIO: Criminal intent as well as the will to commit a crime is always
presumed to exist on the part of the person who executes an act which the law punishes, unless the contrary shall appear. If an act is proven to be unlawful, then intent will be presumed prima facie.