Case No.

13 (Nino)
Ysidoro v. People
G.R. No. 192339, 12 November 2012

The main issue of this case is whether or not acting in good faith can be used as a defense in committing
Technical Malversation. Technical Malversation is when a public official uses public funds or property
under his administration to any public use other than that for which such fund or property were
appropriated by law or ordinance.

The offense is mala prohibita, hence the prohibited act is not inherently immoral but becomes a criminal
offense because positive law forbids its commission.  It is the commission of an act as defined by the law,
and not the character or effect thereof. That determines whether or not the provision has been violated.
Hence, malice or criminal intent is completely irrelevant.

Case No. 14 (Darren)

People v. Pugay
L-74324, 17 November 1988

The issue of the case is whether or not the accused, both Samson and Pugay are guilty of the crime of
murder after Pugay poured the gasoline on the victim and Samson setting the victim on fire. There is
nothing in the records showing that there was previous conspiracy or unity of criminal purpose and
intention between the two accused-appellants and no animosity between the deceased and the accused
were shown.

The respective criminal responsibility of Pugay and Samson arising from different acts directed against
the deceased is individual and not collective, and each of them is liable only for the act committed by
him. Hence, Pugay can only be convicted of the crime of homicide through reckless imprudence since
after failing to exercise all the diligence necessary to avoid every undesirable consequence arising from
any act that may be committed by his companions. It is presumed that a person must always use
common sense and exercise due reflection in all his acts as it carries out his duty to be cautious and
prudent, if not from instinct, then through fear of incurring punishment. As per Samson, although he
merely intended to set the deceased's clothes on fire and not to kill him, he is still held liable as Art 3 of
the RPC provides that criminal liability shall be incurred by any person committing a felony although the
wrongful act done be different from that which he intended.

Case No. 15 (Andrea)

Ivler v. San Pedro
G.R. No. 172716, 17 November 2010

This case tackles the issue of the Double Jeopardy. Reason and precedent both coincide in that once
convicted or acquitted of a specific act of reckless imprudence, the accused may not be prosecuted
again for that same act. The essence of the quasi offense of criminal negligence under article 365 of the
Revised Penal Code lies in the execution of an imprudent or negligent act that, if intentionally done,
would be punishable as a felony. The law penalizes thus the negligent or careless act, not the result
thereof. Moreover, as the careless act is single, whether the injurious result should affect one person or
several persons, the offense (criminal negligence) remains one and the same, and cannot be split into
different crimes and prosecutions.

Case No. 16 (Joseph)

Villarreal v. People
G.R. No. 151258, 1 February 2012

The Court of Appeals set aside the charge of conspiracy by the trial court in Criminal Case No. C-38340
and modified the criminal liability of each accused according to individual participation. The court a quo
found that pursuant to Article 4 (1) of the Revised Penal Code, Artemio Villareal was guilty of homicide,
as it was the direct, natural and logical consequence of the physical injuries they had intentionally
inflicted. The CA ruled that there could have been no conspiracy since the neophytes, including Lenny
Villa, had not knowingly consented to conduct hazing during the initiation rites. The accused, therefore,
was liable only for the consequence of his own individual act.

Case No. 17 (EC)

People v. Guillen
L-1477, 18 January 1950

The issue in this case is whether or not Guillen is guilty of the complex crime murder, owing to the death
of Simeon Varela, and multiple frustrated murder. Guillen is still criminally liable although the wrongful
act done be different from that which he intended. His intent was to throw the grenade towards
President Manuel Roxas, but this resulted to murder and less serious injuries to other persons. This falls
under “aberratio ictus” or mistake in the blow.

Case No. 18 (Edward)

People v. Sabalones
G.R. No. 123485, 31 August 1998

In the case, the trial court was said to have mistakenly contemplated the presence of abberatio ictus or
mistake in the blow because of the lack of precision of the appellants which caused the death and
injuries of the sons of Maj. Juan Tiempo. Although the court ruled that citing error in personae would be
more apt for the case as the appellants intended to shoot someone else, the mistake was immaterial.
According to Art. 4, Par. 1 of the RPC, Criminal liability shall be incurred by any person committing a
felony (delito) although the wrongful act done be different from that which he intended. Citing either
mistake will not diminish the culpability of the appellants. The court held that “mistake in the identity of
the victim carries the same gravity as when the accused zeroes in on his intended victim.”

Case No. 19 (Mich)

People v. Opero
G.R. No. L-48796, 11 June 1981

The issue in the case is whether or not the accused should be convicted of the complex crime of robbery
with homicide. The appellant advances the theory that he never intended to kill the deceased, hence his
liability should only be for robbery. The victim died of asphyxiation by suffocation after Opero put a
“pandesal” in the former’s mouth to prevent her from making noise. However, the fact that the victim
was hogtied aggravates the crime as this disallowed her from removing the “pandesal” in her mouth
which could have avoided her death.

It is a settled doctrine that when death supervenes by reason or on the occasion of the robbery, it is
immaterial that the occurrence of death was by mere accident. It was been repeatedly held that when
direct and intimate connection exists between the robbery and the killing, regardless of which of the
two precedes the other, or whether they are committed at the same time, the crime committed is a
special complex crime of robbery with homicide.

Case No. 20 (Franz)

People v. Albuquerque
G.R. No. 38773, 19 December 1933

The issue being discussed in this case is whether or not the appellant acted in self-defense or is guilty of
crime of homicide?

The respondent is guilty of homicide. However, the degree of penalization was lowered considering
mitigating circumstances in favor of the appelant: 1) lack of intention to cause so grave an injury as the
death of the deceased; 2) voluntarily surrendered himself to the authorities; and 3) acted under the
influence of passion and obfuscation.

Case No. 21 (Rhett)

Bataclan v. Medina
L-10126, 22 October 1957

Whether or not the proximate cause of the death of Bataclan, a passenger which was trapped, was the
overturning of the bus or the fire that burned the bus, including the 4 passengers left inside. 

The overturning of the bus was the proximate cause of the death. The leaking of the gas and the
existence of the torch were both expected results following the natural and logical sequence of events
following the the overturning of the bus. Both are inefficient intervening causes, hence not a source of
criminal liability.

Case No. 22 (Robert)

Wacoy v. People
G.R. No. 213792, 22 June 2015

It is well-settled that if the victim dies because of a deliberate act of the malefactors, intent to kill is
conclusively presumed. In such case, even if there is no intent to kill, the crime is Homicide because with
respect to crimes of personal violence, the penal law looks particularly to the material results following
the unlawful act and holds the aggressor responsible for all the consequences thereof.
In determining the presence of this circumstance, it must be considered that since intention is a mental
process and is an internal state of mind, the accused's intention must be judged by his conduct and
external overt acts.

Case No. 23 (Owen)

People v. Iligan
G.R. No. 75369, 26 November 1990

The issue is whether or not the accused, by hacking blow on the victim’s head, is criminally liable for the
cause of the death of the victim.

Based on the doctrine that “el que es causa de la causa es causa del mal causado” (he who is the cause
of the cause is the cause of the evil caused). In the case at bar, while the accused’s blow on the victim’s
head might not have been the direct cause, it was the proximate cause of the latter’s death.

Proximate legal cause is defined as "that acting first and producing the injury, either immediately or by
setting other events in motion, all constituting a natural and continuous chain of events, each having a
close causal connection with its immediate predecessor, the final event in the chain immediately
effecting the injury as a natural and probable result of the cause which first acted, under such
circumstances that the person responsible for the first event should, as an ordinarily prudent and
intelligent person, have reasonable ground to expect at the moment of his act or default that an injury
to some person might probably result therefrom.”

Case No. 24 (Paula)

Urbano v. IAC
G.R. No. 72964, 7 January 1988

The issues in this case is whether or not there was an efficient intervening cause from the time Javier
was wounded until his death, which would exculpate Urbano from any liability for Javier's death

A prior and remote cause cannot be made the be of an action if such remote cause did nothing more
than furnish the condition or give rise to the occasion by which the injury was made possible. If there
intervened between such prior or remote cause and the injury a distinct, successive, unrelated, and
efficient cause of the injury, even though such injury would not have happened but for such condition or
occasion. If no danger existed in the condition except because of the independent cause, such condition
was not the proximate cause. And if an independent negligent act or defective condition sets into
operation the instances which result in injury because of the prior defective condition, such subsequent
act or condition is the proximate cause.

Case No. 25 (Patrick)

People v. Abarca
G.R. No. 74433, 14 September 1987

Whether or not Abarca committed frustrated murder to Amparados.

Art 247 of the RPC provided that death under exceptional circumstances is not murder and, along with
infliction of serious physical injury, shall only be punishable by destierro. Moreover, if a person shall
inflict upon them physical injuries of any other kind, he shall be exempt from punishment. An example
of such exceptional circumstances as per Art 247 is “any legal married person who, having surprised his
spouse in the act of committing sexual intercourse with another person”

The Court ruled that the appellant cannot be held liable for frustrated murder for the injuries suffered
by the Amparados.

Case No. 26 (August)

Intod v. CA
G.R. No. 103119, 21 October 1992

Whether or not the petitioner Sulpicio Intod is guilty of attempted murder. 

Petitioner shoots the place where he thought his victim would be, although in reality, the victim was not
present in the place and the petitioner failed to accomplish his end. Factual impossibility occurs when
extraneous circumstances unknown to the actor or beyond his control prevent the consummation of the
intended crime. Although there was no actual felony, the intent to kill was present and there would
have been a murder if the victim was actually present in the scene of the crime. Hence Intod is guilty of
attempted murder.

Case No. 27 (Eli)

Jacinto v. People
G.R. No. 162540, 13 July 2009

Whether or not crime of qualified theft was actually committed by the petitioner.

Petitioner Jacinto is criminally liable for an impossible crime which is defined in par 2 Art. 4 and Art. 59
of the Revised Penal Code, respectively. Petitioner had performed all the acts to consummate the crime
of qualified theft at the time she took possession of the check meant for Mega Foam. But if it had not
been for the inherent impossibility of accomplishing such felonious act, which progressed when the
check she received was actually a dishonored check, factual impossibility prevented such crime from
being produced.