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plaintiff-appellee, vs. RENATO MONTIERO Y
RAMIREZ, accused-appellant. (People v. Montiero y Ramirez, G.R. No.
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PHIL 950-958)
91-117)
7. ID.; ID.; ADMISSIBILITY; ACCUSED'S SPONTANEOUS AND
VOLUNTARY VERBAL CONFESSION MADE IN A PRIVATE MEETING,
ADMISSIBLE IN EVIDENCE. — InPeople v. Andan (269 SCRA 95), the
accused's spontaneous and voluntary verbal confession made in
a private meeting with the municipal mayor was admitted in evidence because
the same was not covered by the requisites of Section 12 (1) and (3) of Article III
of the Constitution.
8. ID.; ID.; EXTRA-JUDICIAL CONFESSION; NOT A SUFFICIENT
GROUND FOR CONVICTION UNLESS CORROBORATED BY EVIDENCE OF
CORPUS DELICTI; CASE AT BAR. — Under Rule 133, Section 3 of the Rules of
Court, an extra-judicial confession shall not be sufficient ground for conviction,
unless corroborated by evidence of corpus delicti, which is defined as the body of
the crime and, in its primary sense, means a crime has actually been committed.
Applied to a particular offense, it is the actual commission by someone of the
particular crime charged. In this case, aside from the admission made by
accused-appellant, the bruised and battered body of the victim herself recovered
at the exact spot described by accused-appellant conclusively established the
corroborating evidence of corpus delicti.
(People v. Licayan y Sucano, G.R. No. 144422, [February 28, 2002], 428 PHIL
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332-351)
But assuming that the motive of the accused was really good, does this mean
that criminal intent on her part is thus completely ruled out? WE do not believe
so. A good motive, as we have earlier intimated, is not incompatible with an
unlawful intent. One may be convicted of a crime whether his motive appears to
be good or bad or even though no motive is proven. A good motive does not
prevent an act from being a crime. (People ex rel, Hegeman v. Corrigan, 87 N.E.
792, 796; 195 N.Y. 1, quoting People v. Molineux, supra; Clark, Cr. Law, sec. 14;
People v. Weiss, 300 N.Y.S. 249, 255; 252 App. Div. 463). A classic example
is euthanasia or mercy killing. It is condemned by law although the motive may
be to spare a hopeless patient prolonged suffering And if a father drowns his
child who is five years of age to save it from starving, he is guilty of parricide
though he was actuated by a good motive — love for the child (People v. Kirby, 2
Parker Cr. R., N.Y., 28. See also U.S. v. Marmon, 45 Fed. 414. Both are cited in
The Revised Penal Code, Francisco, supra). The father or brother of a rape
victim, who kills the rapist long after the commission of the rape, to avenge the
victim's defloration, is not exempt from penal liability. A son killing his sleeping
father, who used to beat up his hardworking mother, to relieve his good mother
from so much misery, does not justify the parricide. So also, if a person cuts off
the foot of a mischievous child to prevent if from doing further mischief with its
foot, and thus save it from possible criminal liability, that person stands liable for
physical injuries. True enough, the act involved in the instant case, which is the
beating of a child, is less serious than those involved in the above-cited cases,
but the fact that an act is less serious than another does not mean that it is not
criminal. Other examples can be catalogued ad infinitum. Thus, our penal code
provides specific penalties for specific crimes, depending, generally, on their
seriousness. (Bagajo v. Marave, G.R. No. L-33345, [November 20, 1978], 176
LLpr|||
PHIL 20-50)