Case Digest: US vs.

Fowler 1 Phil 614

Title: US v. Fowler, 1 Phil. 614
Subject Matter: Applications of the provisions of Art. 2 of the Revised Penal Code

Facts:

In August 12, 1901, the defendants were accused of the theft of 16 champagne bottles
worth 20 dollars while on board the vessel, “Lawton”. The counsel for defendants
alleged to the Court of First Instance of Manila that they were without jurisdiction over
the crime charged. Since it happened in the high seas and not in the city of Manila or in
the territory in which the jurisdiction of the court extends, they asked that the case be
dismissed.

Issue:

Whether or not the Court of First Instance of Manila has jurisdiction over the criminal
case theft committed on board while navigating on high seas on a vessel not registered
in the Philippines.

Held:

No. The Philippine court has jurisdiction over the crime of theft committed on high seas
on board a vessel not registered or licensed in the Philippines. The English Rule states
that such crimes are triable in our country when crimes are committed on board a
foreign vessel sailing from a foreign port and which enters the Philippine waters. In the
case at bar, the vessel Lawton was navigating the high seas at the commission of the
crime. Given the location of the vessel at the time, such act is not triable within our
jurisdiction.

Case Digest: French Rule-US vs Bull 15 Phil 7, 14

Case Title: US vs Bull, 15 Phil 7
Subject Matter: Applicability of Art. 2 of the Revised Penal Code
Facts:

On December 2, 1908, a steamship vessel engaged in the transport of animals named

Stanford commanded by H.N. Bull docked in the port of Manila, Philippines. It was
found that said vessel from Ampieng, Formosa carried 674 heads of cattle without
providing appropriate shelter and proper suitable means for securing the animals which
resulted for most of the animals to get hurt and others to have died while in transit.

This cruelty to animals is said to be contrary to Acts No. 55 and No. 275 of the
Philippine Constitution. It is however contended that cases cannot be filed because
neither was it said that the court sitting where the animals were disembarked would take
jurisdiction, nor did it say about ships not licensed under Philippine laws, like the ships
involved.

Issue:

Whether or not the court had jurisdiction over an offense committed on board a foreign
ship while inside the territorial waters of the Philippines.

Held:

Yes. When the vessel comes within 3 miles from the headlines which embrace the
entrance of Manila Bay, the vessel is within territorial waters and thus, the laws of the
Philippines shall apply. A crime committed on board a Norwegian merchant vessel
sailing to the Philippines is within the jurisdiction of the courts of the Philippines if the
illegal conditions existed during the time the ship was within the territorial waters -
regardless of the fact that the same conditions existed when the ship settled from the
foreign port and while it was on the high seas,

In light of the above restriction, the defendant was found guilty and sentenced to pay a
fine of two hundred and fifty pesos with subsidiary imprisonment in case of insolvency,
and to pay the costs.

Case Digest: US vs. Ah Chong, 15 Phil 499

U.S. vs. Ah Chong (15 Phil. 488)

FACTS:
The defendant, Ah Chong, was employed as a cook at “Officers’ quarters. On the night,
the defendant, who had received for the night, was suddenly awakened by some trying
to force open the door of the room. He sat up in bed and called out twice, “Who is
there?” He heard no answer and was convinced by the noise at the door that it was
being pushed open by someone bent upon forcing his way into the room. The
defendant, fearing that the intruder was a robber or a thief, leaped to his feet and called
out: “If you enter the room, I will kill you.” He was struck just above the knee by the edge
of the chair and he thought that the blow had been inflicted by the person who had
forced the door open, whom he supposed to be a burglar. Seizing a common kitchen
knife which he kept under his pillow, the defendant struck out wildly at the intruder who,
it afterwards turned out, was his roommate. The roommate eventually died.

ISSUE:
Whether or not Ah Chong is liable for the death of his roommate.

HELD:
NO. Ah Chong was acquitted.

RATIO:
The decision of the lower court was reversed. The case was a “mistake of fact” resulting
to self-defense justified under Article 11(1) of the Revised Penal Code where there is
(1) unlawful aggression, (2) reasonable necessity of the means employed to prevent or
repel it, and (3) lack of sufficient provocation on the part of the person defending
himself. Had the deceased be a robber as he thought, his actions would not be
criminally liable.
Some maxims cited:

Actus non facit reum nisi mens sit rea, “the act itself does not make man guilty unless
his intention were so;”
Actus me incito factus non est meus actus, “an act done by me against my will is not my
act;”

People vs. Gullen, 85

January 18, 1950 | G.R. No. L-1477

People of the Philippines, plaintiff-appellee

Julio Guillen, defendant-appellant

FACTS:
On March 10, 1947, in an event sponsored by the Liberal Party at Plaza Miranda in
Quiapo, Manila, Guillen planted a hand grenade near the stage and threw another one
toward then President Manuel Roxas in an apparent assassination attempt born out of
Guillen's spite for the President over the latter's perceived failure to fulfill his promises
and his call for the passage of the so-called parity measure. General Castaneda
managed to kick the grenade off the stage. However, its explosion caused the death of
Simeon Varela (Barrela). It also caused the injuries of Alfredo Eva, Jose Fabio, Pedro
Carillo, and Emilio Maglalang.

Guillen pleaded not guilty to the consequent charges of murder and multiple frustrated
murder filed against him. At one point, he even tried to use the insanity excuse, but he
was found to have been mentally stable.

Later on, by his own admission, he confessed to his crimes. He was subsequently found
guilty of all the charges and was sentenced to death.

ISSUE:

Whether or not the conviction of the accused was proper.

HELD:

No, the SC ruled that Guillen's actions on March 10, 1947 and their penalties were
covered by Art. 48 of the RPC, not sub-section 1 of Art. 49. The Court said that by a
single act -- throwing a hand grenade at President Roxas -- he committed two grave
felonies:
(a) murder and (b) multiple attempted murder.

At the same time, the murder of Varela was attended by the qualifying circumstance of
treachery, given that the victim was not able to put up a defense against the attack,
even though he was not the principal target.

And lastly, the Court ruled that the injuries sustained by the other victims constitute
attempted and not frustrated murder. The Court reasoned that Guillen's failed attempt to
kill President Roxas was due to some reason or accident (General kicking the grenade
off the stage) other than his own spontaneous desistance.

In the end the Court affirmed the death sentence handed out by the lower court.
 Case Digest: US vs. Catangay, 28 Phil 490

Case Digest: P vs. Bayona, 61 Phil 181

Case Digest: P vs. Neri, 140 SCRA 406

Case Digest: P vs. Estoista, 93 Phil 647

Facts:
Appellant was prosecuted for homicide through reckless imprudence and illegal
possession of firearm. He was acquitted of the first offense and found guilty of the
second for which he was sentenced to one year imprisonment.

Issues:
Whether or not the form of the penalty and the duration of the imprisonment imposed on
the appellant infringe the constitutional provision against cruel and hard punishment.

Held:
NO. Confinement from 6 to 10 years of possessing or carrying of firearm is not cruel or
unusual, having due regard to the prevalent conditions which the law proposes to
suppress or curb. The rampant lawlessness against property, person, and even the very
security of the Government, directly traceable in large measure to promiscuous carrying
and use of powerful weapons, justify imprisonment which in normal circumstances
might appear excessive. If imprisonments from 5 to 10 years is out of proportion to the
present case in view of certain circumstances, the law is not to be declared
unconstitutional for this reason. The constitutionality of an act of the legislature is not to
be judged in the light of exceptional cases.
Judgment is MODIFIED, sentencing the appellant to imprisonment for five years.
 Case Digest: P vs. Taneo, 58 Phil 255, 257
People v. Taneo (CASE DIGEST)

G.R. No. L-37673

March 31, 1933

TOPICS: Criminal Law, Somnambulism, Sleep Walking, Legal Medicine

FACTS:

Potenciano Tadeo lived with his wife in his parent’s house. In January 1932, a fiesta
was being celebrated, and visitors were entertained in the house including Fred Tanner
and Luis Malinao. Early that afternoon, Potenciano Taneo, went to sleep and while
sleeping, he suddenly got up, left the room bolo in hand and, upon meeting his wife who
tried to stop him, he wounded her in the abdomen. Taneo attacked Tanner and Malinao
and tried to attack his father after which he wounded himself. Potenciano’s wife who
was then seven months pregnant, died five days later as a result of her wound, and also
the foetus which was asphyxiated in the mother’s womb.

Taneo was charged with parricide. From this sentence, the defendant appealed.

It appears from the evidence that the day before the commission of the crime the
defendant had a quarrel over a glass of “tuba” with Enrique Collantes and Valentin
Abadilla. On the day of the commission of the crime, it was noted that the defendant
was sad and weak, and early in the afternoon he had severe stomachache. The
defendant states that when he fell asleep, he dreamed that Collantes was trying to stab
him with a bolo while Abadilla held his feet, by reason of which he got up; and as it
seemed to him that his enemies were inviting him to come down, he armed himself with
a bolo and left the room. At the door, he met his wife who seemed to say to him that she
was wounded. Then he fancied seeing his wife really wounded and in desperation
wounded himself. As his enemies seemed to multiply around him, he attacked
everybody that came his way.

The evidence shows that the defendant not only did not have any trouble with his wife,
but that he loved her dearly. Neither did he have any dispute with Tanner and Malinao,
or have any motive for assaulting them.

ISSUE:

Whether or not Taneo is criminally liable.

RULING:

No. The Court concluded that the defendant acted while in a dream. His acts were not
voluntary in the sense of entailing criminal liability.

The Court took the special circumstances of the case, in which the victim was the
defendant’s own wife whom he dearly loved, and taking into consideration the fact that
the defendant tried to attack also his father, in whose house and under whose
protection he lived, besides attacking Tanner and Malinao, his guests, whom he himself
invited as may be inferred from the evidence presented, the Court found not only a lack
of motive for the defendant to voluntarily commit the acts complained of, but also
motives for not committing said acts.

Doctor Serafica, an expert witness in this case, is also of the same opinion. The doctor
stated that considering the circumstances of the case, the defendant acted while in a
dream, under the influence of a hallucination and not in his right mind.

The Court found that the defendant is not criminally liable for the offense with which he
is charged, and it is ordered that he be confined in the Government insane asylum,
whence he shall not be released until the director thereof finds that his liberty would no
longer constitute a menace.

PEOPLE vs. TANEO

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People vs. Taneo

March 31, 1933 (58 Phil 255)

PARTIES:

Plaintiff and appellee: People of the Philippines

Defendants and appellant: Potenciano Taneo

FACTS:

On January 16, 1932, in the house of Potenciano Taneo’s parents in Dolores, Ormoc,
Leyte, because of severe stomachache, Potenciano slept early. While sleeping, he
suddenly got up, left the room with a bolo in hand and upon meeting his wife who tried
stop him, he wounded her int eh abdomen. Several others were also attacked, this
includes his father, and his guests, Fred Tanner and Luis Malinao. It was claimed that
he was dreaming when the crime happened. The trial court found Potenciano guilty of
parricide and was sentenced to reclusion perpetua.

ISSUE:

WON the defendant is criminally liable.

HELD:

No. The defendant acted while in a dream and his acts with which he was charged were
not voluntary in the sense of entailing criminal liability. The expert witness claimed that
the defendant was under the influence of hallucination and not in his right mind. The
defendant is not criminally liable however, he was ordered to be confined in an insane
asylum.
Case Digest: P vs. Usual, 58 SCRA 138, 144