SADANG, PHILIP DUVAN B.

A–1

CASE DIGEST IN CRIMINAL LAW 1

1. Edgardo Gaanan v. Intermediate Appellate Court, G.R. No. L-69809, October 16, 1986

Facts:

Complainant Atty. Tito Pintor discussed the withdrawal of a complaint with client Manuel Montebon
over a telephone call. Appellant, a lawyer, was asked by Leonardo Laconico to secretly listen to the
conversation using an extension telephone. Appellant overheard the conditions for withdrawal, leading
to a subsequent arrest during a money exchange related to the settlement.

Issue:

Whether the use of an extension telephone constitutes a violation of Republic Act (RA) No. 4200, the
Anti-Wiretapping Act.

Ruling:

The court ruled in favor of the petitioner, stating that an extension telephone is not covered by the term
"device or arrangement" in RA No. 4200. The court acquitted the petitioner of the violation of the Anti-
Wiretapping Act.

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2. Benedicto v. Court of Appeals, 416 SCRA 722

Facts:

On December 27, 1991, Mrs. Imelda Marcos, Roberto S. Benedicto, and Hector T. Rivera were indicted
for violating Central Bank Circular No. 960, failing to report foreign exchange earnings. Legal proceedings
followed, with amendments to Circulars No. 1318 and No. 1353. On September 19, 1993, Benedicto and
Rivera were allowed to return to the Philippines, facing criminal charges. They pleaded not guilty on
February 28, 1994. However, on August 11, 1994, they moved to quash the charges, citing grounds like
lack of jurisdiction and the repeal of Circular No. 960. The trial court denied the motion on September 6,
1994, triggering subsequent motions and denials.

Issues:

1. Extinction of criminal liability with the repeal of Circular No. 960

2. Exemption from the Central Bank’s reporting requirement

3. Grant of absolute immunity through a compromise agreement with the government

Ruling:

The Court of Appeals found no grave abuse of discretion in denying the petitioners' Motions to Quash,
except for Criminal Case No. 91-101884. The dismissal of the petitions was based on the merit, and the
order denying the Motion to Quash for Criminal Case No. 91-101884 was nullified. The case was
dismissed. Costs were imposed against the petitioners.

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3. Rosario Nasi-Villar v. People, G.R. No. 176169, November 14, 2008

Facts:

Rosario Nasi-Villar filed a Petition for Review under Rule 45, challenging the Decision and Resolution of
the Court of Appeals dated 27 June 2005 and 28 November 2006, respectively. The case originated from
an Information filed on 5 October 1998, charging Nasi-Villar and Dolores Placa with illegal recruitment in
January 1993. The trial court found Nasi-Villar guilty, sentenced her to an indeterminate penalty, and
ordered her to pay temperate damages to the offended party.

Issue:

The main issue raised in the appeal was the alleged error by the trial court in finding Nasi-Villar guilty of
illegal recruitment under Republic Act No. 8042 (RA 8042) instead of the Labor Code.

Ruling:

The Court of Appeals affirmed the decision but modified the penalty for Nasi-Villar, ordering temperate
damages. It acknowledged the error in applying RA 8042 due to the acts occurring in 1993, predating the
law. However, it upheld the conviction under the Labor Code, specifically Art. 38, Art. 13(b), and Art. 39.
Nasi-Villar appealed to the Supreme Court, arguing against retroactive application of RA 8042 as a
violation of the constitutional prohibition against ex post facto laws.

The Supreme Court denied the petition, upholding the Court of Appeals' decision. It emphasized that the
real nature of the crime is determined by the facts in the complaint or information. The Court found no
violation of ex post facto laws and no retroactive application of RA 8042. The conviction under the Labor
Code was affirmed.

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4. Liang v. People, G.R. No. 125685, Jan. 28, 2000 Asian Development Bank

Facts:

In 1994, an economist from the Asian Development Bank (ADB) faced defamation charges in the
Metropolitan Trial Court (MeTC) related to remarks about a colleague, Joyce Cabal. The MeTC issued an
arrest warrant, but after the Department of Foreign Affairs (DFA) claimed immunity for the petitioner
under Section 45 of the ADB-Philippine Government Agreement, the MeTC dismissed the cases without
notifying the prosecution.

Issue:

The key question is whether the MeTC's dismissal, based on the DFA's communication asserting
immunity, violated due process and if the petitioner is entitled to immunity under Section 45.

Ruling:

The court ruled that DFA's immunity decision isn't binding, and dismissing cases without notifying
prosecution violated due process. Section 45's immunity isn't absolute, limited to acts in an "official
capacity." Prosecution should challenge DFA protocol. Immunity doesn't cover crimes like defamation;
officials may be personally liable for unauthorized acts. Citing the Vienna Convention, diplomatic agents
have immunity only in non-official activities. The court rejected jurisdiction arguments, affirming the
RTC's decision.

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5. People v Maximo Dela Peña, G.R. No. 219581, January 31, 2018

Facts:

Maximo De La Peña appealed his piracy conviction under PD 532. He was accused of forcefully taking
items, including copra, watches, and cash, along a river bank in Samar, Philippines. De La Peña pleaded
not guilty, presenting an alibi of fishing in Daram, Samar, during the incident. The prosecution, led by
Julita Nacoboan, claimed De La Peña and armed companions seized their boat, taking belongings and
unloading copra on an island.

Issue:

The key issue was whether De La Peña was guilty of piracy under PD 532. He argued that the
prosecution failed to prove piracy's elements.
Ruling:

The Court affirmed the piracy conviction, citing the Information's sufficient details and rejecting De La
Peña's lack of positive identification claim. The penalty was reclusion perpetua without parole due to the
death penalty prohibition by Republic Act No. 9346. The Court upheld the modification by the Court of
Appeals, awarding temperate damages instead of actual damages, and dismissing other damages for
lack of basis. The appeal was denied, affirming De La Peña's guilt of piracy.

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6. US v. Look Chaw, 18 Phil 573

Facts:

The defendant faced a charge of unlawful possession of opium in Cebu, with the case separated from an
unlawful sale charge upon a successful demurrer. Opium was discovered on the steamship Erroll under
the defendant's control during inspection, and the defendant admitted ownership, revealing an intent to
sell the contraband in Mexico. The opium, found on an English vessel bound for Mexico, was seized as
evidence.

Issues:

Whether the court had jurisdiction to try the case.

Whether the facts constituted a crime, considering the possession of opium on a foreign vessel in
transit.

Ruling:

The trial court claimed jurisdiction over the crime committed on the Cebu wharf, leading to the
defendant receiving a five-year imprisonment, a P10,000 fine, and opium confiscation. On appeal, the
higher court upheld the conviction but shortened the sentence to six months and reduced the fine to
P1,000. It highlighted the local jurisdiction, emphasizing the violation occurred when the opium landed
in the Philippines. Additionally, the court noted that the quantity of the seized drug didn't warrant the
maximum penalties prescribed by law.

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7. US v. Wong Cheng, 46 Phil 729

Facts:
The case involves an appeal by the Attorney-General seeking the revocation of the Court of First
Instance of Manila's order. The lower court sustained the defendant's demurrer, arguing lack of
jurisdiction over the information accusing the appellee of illegally smoking opium on the English
merchant vessel Changsa, anchored in Manila Bay.

Issues:

The main issue is whether the Court of First Instance of Manila has jurisdiction over offenses, such as
illegal opium smoking, committed aboard foreign merchant vessels within the jurisdictional waters of
the Philippines. The key legal question is whether the territorial principle or comity of nations should
apply.

Ruling:

The court revokes the order of the lower court and remands the case for further proceedings. The ruling
emphasizes that under the territorial principle, crimes committed aboard foreign vessels within three
miles of the Philippine territory are triable in local courts. It rejects the French rule and affirms the
application of the English rule, consistent with prevailing theories in the United States. The court
highlights that the possession of prohibited substances aboard foreign vessels in transit generally does
not constitute a crime, but once such items are landed on Philippine soil, the violation of local laws
occurs. Smoking opium within Philippine territorial limits, even on a foreign vessel, is deemed a breach
of public order, justifying local jurisdiction. The court concludes that allowing such actions would be
subversive of public order and orders the case to proceed in the Court of First Instance of Manila.

The Court of Appeals rules in favor of the Attorney-General, asserting the jurisdiction of local courts over
offenses committed aboard foreign vessels within the territorial waters of the Philippines. The order of
the Court of First Instance of Manila is revoked, and the case is remanded for further proceedings.

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8. People v. Ah Sing, 36 Phil 978

Facts:

The defendant, a Chinese national employed as a fireman on the foreign steamship Shun Chang, arrived
at the port of Cebu on April 25, 1917, after a direct voyage from Saigon. Upon inspection, authorities
found eight cans of opium hidden in the ashes below the boiler of the ship. The defendant admitted to
purchasing the opium in Saigon and having it in his possession during the journey.

Issues

Whether the crime of illegal importation of opium into the Philippine Islands has been proven.
The applicability of previous court decisions, specifically United States vs. Look Chaw and United States
vs. Jose, to the present case.

Ruling:

The Court affirms the trial court's judgment, finding the defendant guilty beyond a reasonable doubt of
violating section 4 of Act No. 2381 (the Opium Law). The defendant is sentenced to two years
imprisonment, a fine of P300, or subsidiary imprisonment in case of insolvency, and is ordered to pay
the costs.

The court distinguishes the present case from United States vs. Look Chaw, emphasizing differences in
charges, transit status, and the landing of opium on Philippine soil. It also addresses United States vs.
Jose, emphasizing the need for the government to prove or raise a presumption that the vessel carrying
the prohibited drug came from a foreign country. The court interprets section 4 of Act No. 2381, holding
that the act of bringing a prohibited drug into the Philippine Islands is complete when the drug is found
under a person's control on a vessel arriving directly from a foreign country within the jurisdictional
limits. The court rejects any doubt about the authority of previous views and concludes that the
defendant intended to bring the opium into the Philippine Islands.

The judgment is affirmed, and the defendant is found guilty of illegal importation of opium from a
foreign country into the Philippine Islands. The court clarifies that these findings do not apply to foreign
vessels in transit. The sentence imposed by the trial court is within the legal limits and is upheld with
costs against the appellant.

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9. Valeroso v. People, G.R. No. 164815, February 22, 2008 (546 SCRA 450)

Facts:

On July 10, 1996, police officers received a warrant to arrest petitioner Sr. Insp. Jerry C. Valeroso for
kidnapping with ransom. The police team conducted surveillance, located the petitioner, and arrested
him at the Integrated National Police Central Station in Quezon City. During a search, a Charter Arms
revolver was found tucked in petitioner's waist without the necessary license or permit. The firearm was
registered to another person, Raul Palencia Salvatierra, and not issued to the petitioner.

Issues:

Legality of Arrest and Search: Petitioner claimed his arrest and the subsequent search were illegal.

Possession of Firearm: Petitioner argued he had legal authorization for the firearm based on a
Memorandum Receipt issued by the police.

Admissibility of Evidence: Petitioner contested the admissibility of the firearm as evidence, asserting it
was not formally offered by the prosecution.
Ruling:

Legality of Arrest and Search: The court upheld the legality of the arrest and search, relying on the trial
court's findings and the credibility of witnesses.

Possession of Firearm: The court rejected petitioner's claim of legal authorization, stating the firearm
was not issued to him but to another person. The Memorandum Receipt was deemed irregular.

Admissibility of Evidence: The court noted that the firearm and ammunition were properly offered as
evidence, and the non-presentation of the firearm during trial did not hinder the conviction.

The court affirmed the decision finding the petitioner guilty of illegal possession of a firearm, with a
modified penalty based on the prevailing law. The firearm and ammunition were ordered confiscated in
favor of the government.

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10. Dorado v. People, G.R. No. 216671, October 3, 2016

Facts:

Jerwin Dorado, a 16-year-old minor, was accused of a crime involving the shooting of Ronald Bonion.
The incident occurred during a feud between Dorado's group and Ronald's group. Dorado allegedly shot
Ronald between the eyes with a sumpak, but Ronald survived due to immediate medical assistance.

During the trial, the prosecution failed to establish that Dorado acted with discernment, a crucial factor
in determining criminal liability for minors aged 15 to 18. The court noted that discernment, defined as
the mental capacity to understand the difference between right and wrong, must be proven based on
various factors, including the minor's behavior before, during, and after the commission of the crime.

Issue:

The central issue revolves around whether the prosecution successfully demonstrated that Jerwin
Dorado acted with discernment at the time of the crime. Discernment, in this context, is the key factor
in deciding whether a minor aged 15 to 18 can be criminally prosecuted.

Ruling:

The court ruled in favor of Jerwin Dorado, concluding that the prosecution did not make an effort to
prove that Dorado acted with discernment during the commission of the crime. Emphasizing that
discernment cannot be presumed, the court applied the principle of liberal construction in favor of the
child in conflict with the law.
As a result, the court deemed Dorado exempted from criminal liability, in accordance with Section 3 of
R.A. No. 9344. However, Dorado was held accountable for civil liability. The court determined that the
crime committed was frustrated homicide, not murder, due to the lack of evidence for evident
premeditation.

Dorado was ordered to undergo an intervention program, and he was directed to pay civil indemnity
and moral damages to the victim, Ronald Bonion. The decision was granted, reversing the initial
judgment of conviction. Copies of the decision were to be furnished to the two houses of Congress for
their information and guidance in future legislation concerning children in conflict with the law.

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11. Hernan v. Sandiganbayan, G.R. No. 217874, December 5, 2017

Facts:

The accused, Hernan, allegedly left an amount of ₱11,300.00 and the corresponding deposit slip with
the bank teller Ngaosi. Upon returning to retrieve the deposit slip, it was discovered that the ₱11,300.00
was not credited to the account of the Department of Transportation and Communication (DOTC) with
the Land Bank and was missing. The accused is being charged with malversation, and there is a
discussion about whether the misappropriation was due to the accused's negligence.

Issue:

Whether the accused, Hernan, should be convicted of malversation, considering the circumstances of
the missing ₱11,300.00, and whether the accused's negligence played a role in the misappropriation.

Ruling:

The court initially affirms the decision of the Sandiganbayan, finding the accused guilty of malversation.
However, the ruling is modified later in the document due to the recent passage of Republic Act No.
10951, which adjusted the penalties for malversation. The court decides to reopen the case, not for
further reception of evidence but to modify the penalty imposed. The new penalty is determined based
on the provisions of the recent law, and the accused is sentenced to the indeterminate penalty of six (6)
months of arresto mayor as the minimum term to three (3) years, six (6) months, and twenty (20) days
of prision correccional as the maximum term.

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12. People v. Estrada, G.R. No. 130487, June 19, 2000 (333 SCRA 699)

Facts:
On December 29, 1994, in Dagupan City, Philippines, the accused-appellant attended a religious
ceremony. During the event, a confrontation ensued when the accused, gripping a knife, refused to
vacate a chair at the altar upon request.SPO1 Francisco intervened, advising the accused to drop the
knife, which he did. Later, it was discovered that the security guard, Rogelio Mararac, sustained fatal
stab wounds during the incident and subsequently died at the hospital. Mararac's autopsy revealed two
stab wounds, causing cardio-respiratory arrest and massive intra-thoracic hemorrhage. The accused-
appellant was later charged under Article 248 of the Revised Penal Code.

Issues:

The accused-appellant raised a motion for reconsideration, asserting insanity as a defense. The trial
court, despite opposition from the City Prosecutor, denied the motion and proceeded with the
arraignment. The accused pleaded not guilty.

The defense argued that the lower court erred in finding the accused guilty of murder and applying
aggravating circumstances, contending that the plea of insanity should exempt the accused.

Ruling:

On June 23, 1997, the trial court convicted the accused of murder and sentenced him to death.
However, the appellate court vacated the decision, citing the trial court's failure to conduct a proper
mental examination. The appellate court emphasized that the trial judge lacked the expertise to
determine the accused's mental health and ordered a remand for a comprehensive mental examination
and further proceedings.

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13. Abdulla v. People, G.R. No. 10129, April 6, 2005 (45 SCRA 78)

Facts:

Spouses Romano filed an action for damages in the amount of P10,000 against Spouses Pariñas, the
latter being the parents of Antonio who is a minor. It was alleged that Spouses Pariñas allowed Antonio
to drive a motor vehicle having a passenger one Editha Romano, and because of his lack of foresight and
experience, the vehicle overturned resulting in the death of Editha.

Defendants, in their answer, set up the defense that they never permitted their son to drive any motor
vehicle, if on the occasion alleged in the complaint, he drove a jeep, it was upon the persistent plea of
Editha Romano. They alleged that the accident, if it happened, was due to her fault and negligence.
After filing their answer, defendant also filed a motion asking that Caridad Donato, wife of defendant
Crisostomo Pariñas, be dropped from the complaint on the ground of misjoinder of parties-defendants,
contending that under Article 2180 of the new Civil Code, the father is primarily responsible for the
damages caused by the minor children, except only in case of his death or incapacity when the mother
also becomes answerable.
Issue:

Whether or not dropping Caridad, mother of Antonio, from the case pursuant to Article 2180 of the Civil
Code was proper.

Ruling:

The Supreme Court held in the affirmative. It ratiocinated as follows: The legal provisions on which the
action of plaintiffs is predicated are Articles2176 and 2180 of the new Civil Code. It appears clear from
the above that whoever by act or omission causes damage to another, there being fault or negligence, is
obliged to pay for the damage done, and this obligation is demandable not only for one's own acts or
omissions, but also for those persons for whom one is responsible. And one of the acts mentioned
therein is "The father and, in case of his death or incapacity, the mother", answers for the damages
caused by their minor children who live in their company. It is therefore clear that the responsibility of
the father and mother is not simultaneous, but alternate, the father being primarily responsible, and the
mother answering only " In case of his death or incapacity. "Since in the instant case the Father is both
living and capable, as can be gleaned from the allegations of the complaint, it follows that it is improper
to join the mother as party-defendant

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14. People v. Urzais, G.R. No. 207662, April 13, 2016

Facts:

The accused, along with co-accused Alex Bautista and Ricky Bautista, faced charges under the Anti-
Carnapping Act with homicide using an unlicensed firearm.

The regional trial court found the accused guilty based on the presumption that possession of a recently
stolen item implies guilt for the entire crime.

The Court of Appeals affirmed the trial court's decision with modifications.

Issues:

Yes, the lower courts erred by convicting based solely on circumstantial evidence, specifically the
accused's possession of the alleged stolen vehicle.

Ruling:

The charge of carnapping is unsupported due to a lack of evidence. The courts relied on circumstantial
evidence, ignoring the accused's explanation that he purchased the vehicle from the Bautista brothers.
The prosecution failed to disprove this defense. The equipoise rule asserts that if evidence allows
multiple interpretations, one favoring innocence and another guilt, it fails the moral certainty test. The
burden of proof rests with the prosecution, and the accused need not establish defenses beyond
reasonable doubt.

The constitutional right to be presumed innocent until proven guilty demands clear and persuasive
prosecution. Proof beyond reasonable doubt is essential, and a conviction based solely on disputable
presumptions is a miscarriage of justice.

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15. People v. Lol-lo and Saraw, G.R. No. 17958, February 7, 1922

Facts:

On or about June 30, 1920, a group of Moros attacked two Dutch boats in the South Seas between the
Islands of Buang and Bukid. The Moros, armed and numbering twenty-four, robbed the boats, brutally
violated two women, and later arrived at Maruro, a Dutch possession. The two women managed to
escape, and the perpetrators, Lol-lo and Saraw, were later arrested in South Ubian, Tawi-Tawi, Sulu,
Philippines. They were charged with piracy in the Court of First Instance of Sulu.

Issue:

The primary issue revolves around the jurisdiction and applicability of the provisions of the Spanish
Penal Code on piracy to the Philippines after it was ceded by Spain to the United States through the
Treaty of Paris. The defense raised a demurrer, arguing that the Court of First Instance lacked
jurisdiction, and questioned the continued validity of the Penal Code provisions.

Ruling:

The court rejected the demurrer, asserting that piracy is a crime against all mankind and has no
territorial limits. It affirmed that the provisions of the Penal Code, specifically Articles 153 and 154,
relating to piracy, still apply in the Philippines after the cession to the United States. The court, applying
a logical construction, substituted "Spain" with "United States" and "Spaniards" with "citizens of the
United States and citizens of the Philippine Islands" in the articles.

Having established jurisdiction and the applicability of the Penal Code, the court found Lol-lo and Saraw
guilty of piracy under the first paragraph of Article 153. Considering aggravating circumstances, including
an offense against chastity and the abandonment of persons without means of saving themselves, the
court sentenced Lol-lo to death by hanging and affirmed Saraw's life imprisonment. Both were ordered
to indemnify the offended parties and share the costs.

The decision was not unanimous, as one justice dissented regarding the death penalty for Lol-lo.

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16. People v. Fausta Gonzales, et al., G.R. No. 80762, March 19, 1990 (183 SCRA 309)

Facts:

The murder of Lloyd Peñacerrada in 1981 in Ajuy, Iloilo, Philippines. Fausta Gonzales and her husband
Augusto Gonzales were initially accused of the crime. Later, Custodio Gonzales, Sr., Custodio Gonzales,
Jr., Nerio Gonzales, and Rogelio Lanida were also implicated. The prosecution's main witness, Jose
Huntoria, alleged that he witnessed the accused attacking and killing Peñacerrada. However, Huntoria
admitted during cross-examination that he couldn't identify who specifically performed the stabbing or
hacking due to the rapid movement of the assailants. The investigation conducted by police authorities
was deemed inadequate and lacking. Patrolman Centeno made errors in his sworn statements regarding
the date of the crime. The investigation by other authorities, including the PC investigators, also raised
doubts as they mentioned four unnamed persons apart from the accused spouses involved in the killing.
Dr. Rojas, who conducted the autopsy on Peñacerrada's body, confirmed 16 wounds, with only five
being fatal. He stated that it was possible multiple weapons caused the wounds, but admitted that one
blade might have caused them all.

Issue:

The primary issue in the case involving Custodio Gonzales, Sr. revolves around the sufficiency of
evidence and the credibility of the prosecution's witness testimony. The key issue centers on whether
there was enough substantial evidence to prove Custodio Gonzales, Sr.'s guilt beyond a reasonable
doubt for the murder of Lloyd Peñacerrada. The case hinged on the testimony of Jose Huntoria, the
prosecution's main witness, who alleged witnessing the attack but couldn't identify the specific
individual responsible for the fatal act due to the rapid movement of the assailants.

The court had to evaluate the credibility of the witness, the inconsistencies in his testimony, the lack of
specificity regarding the accused's involvement, and the absence of concrete evidence linking Custodio
Gonzales, Sr. directly to the murder. The issue was whether the evidence presented was adequate and
reliable enough to establish Custodio Gonzales, Sr.'s guilt in committing the crime beyond a reasonable
doubt.

Ruling:

The Court of Appeals convicted Custodio Gonzales, Sr. based on Huntoria's testimony. However, the
Supreme Court reviewed the case, highlighting the lack of specificity in Huntoria's testimony. Huntoria's
eight-month delay in reporting the incident raised doubts about his credibility, especially since he was
the victim's tenant and stood to benefit from testifying.

The Supreme Court found the prosecution's evidence insufficient. It concluded that there was no specific
act attributed to Custodio Gonzales, Sr. that caused Peñacerrada's death. The lack of evidence to prove
conspiracy and the inconsistencies in Huntoria's testimony led the Court to rule in favor of Custodio
Gonzales, Sr. The conviction was overturned, and Custodio Gonzales, Sr. was acquitted due to
insufficient evidence to establish guilt beyond reasonable doubt.
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17. Calimutan v. People, G.R. No. 152133, February 9, 2006

Facts:

Petitioner Calimutan filed a Petition for Review on Certiorari to reverse the convictions by the RTC and
Court of Appeals, dated 19 November 1998 and 29 August 2001 respectively, for homicide. The victim,
Cantre, died, and conflicting autopsy reports arose: one stating food poisoning and the other citing
traumatic abdominal injury.

Issues:

Conflicting Autopsy Reports: The main issue was the contradictory findings in the autopsy reports on the
cause of the victim's death.

Reasonable Doubt: Whether the conflicting reports raised reasonable doubt regarding Calimutan's
culpability for the victim's death.

Ruling:

The Court found Calimutan guilty beyond reasonable doubt of reckless imprudence resulting in
homicide. Despite acknowledging Calimutan's lack of intent to kill, his action of throwing a stone that
caused the victim's death was deemed reckless imprudence.

Calimutan was sentenced to imprisonment for a minimum of 4 months of arresto mayor to a maximum
of two years and one day of prision correccional. He was also ordered to pay ₱50,000.00 as civil
indemnity for the victim's death and an additional ₱50,000.00 as moral damages to the victim's heirs.

The court upheld the conviction based on reckless imprudence, ruling that Calimutan's act of throwing a
stone led to the victim's death, even without intent to cause harm.

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18. Picart v. Smith Jr., G.R. No. L-12219, March 15, 1918

Facts:

The incident occurred on December 12, 1912, on Carlatan Bridge in La Union. Amado Picart, the plaintiff,
was riding his pony on the bridge when Frank Smith, Jr., the defendant, approached in an automobile at
a speed of 10-12 miles per hour. Smith honked the horn to signal his approach, giving successive
warnings. Picart, perturbed by the situation, pulled his pony toward the right railing of the bridge
instead of moving to the left side. Despite perceiving the horseman's presence, Smith continued driving
toward the center of the bridge, assuming Picart would move to the other side. When it became clear
Picart wouldn't move, Smith attempted to veer right, but the automobile struck the pony's hind leg,
causing it to fall and fatally injuring the horse. Picart suffered injuries as well.

Issue:

Whether Frank Smith's actions constituted negligence and if he should be held liable for the damages
caused to Amado Picart and his horse.

Ruling:

The court applied the standard of conduct expected from a prudent person in a given situation. Smith
should have foreseen the risk and adjusted his driving to avoid the collision. Negligence was established
based on Smith's failure to take precautions, even after realizing the imminent danger to the horse and
rider.

The Supreme Court found Frank Smith liable for negligence. Despite Picart's initial positioning on the
wrong side of the road, Smith failed in his duty to prevent harm once he realized Picart wouldn't move.
Smith's actions, continuing toward the horse without taking precautions, were negligent.

The court referred to a prior case (Rkes vs. Atlantic, Gulf and Pacific Co.) where contributory negligence
did not bar recovery but could reduce the damages awarded. However, in the present case, Smith's
immediate negligence was deemed the primary cause of the accident. The judgment of the lower court
absolving Frank Smith from liability was reversed. Amado Picart was awarded ₱200 for damages,
covering the horse's value, Picart's medical expenses, and other losses. Other damages claimed by Picart
were deemed remote and not recoverable.

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19. Ivler v. Modesto-San Pedro, G.R. NO. 172716

Facts:

The Double Jeopardy Clause prevents a second prosecution for Reckless Imprudence Resulting in
Homicide and Damage to Property.

Criminal Case No. 172716 for Reckless Imprudence Resulting in Slight Physical Injuries, related to injuries
suffered by respondent Evangeline L. Ponce and Criminal Case No. 82366 for Reckless Imprudence
Resulting in Homicide and Damage to Property, linked to the death of respondent Ponce's husband
Nestor C. Ponce and damage to the spouses Ponce's vehicleThe petitioner sought to quash the
Information in Criminal Case No. 82366, arguing it placed him at risk of a second punishment for the
same offense of reckless imprudence.

The Metropolitan Trial Court (MeTC), without addressing the petitioner's motion, proceeded with the
arraignment. Due to the petitioner's absence, the MeTC canceled his bail and issued an arrest order. The
petitioner criticizes the Regional Trial Court (RTC) for not addressing the substance of his petition in
S.C.A. 2803. Citing legal precedent, the petitioner contends that his constitutional right not to face
double jeopardy prohibits his prosecution in Criminal Case No. 82366 after being previously convicted in
Criminal Case No. 82367 for the same reckless imprudence offense. The petitioner asserts that the
various consequences of the crime only determine the penalty.

Issues:

Whether the petitioner forfeited his right to seek relief in S.C.A. 2803 when the MeTC ordered his arrest
following his non-appearance at the arraignment in Criminal Case No. 82366 and if not, whether the
petitioner's constitutional right under the Double Jeopardy Clause prevents further proceedings in
Criminal Case No. 82366.

Ruling:

The constitutional protection against double jeopardy prevents further proceedings in Criminal Case No.
82366. Reckless Imprudence is a single crime, and its consequences on persons and property are
relevant only to determine the penalty.

Prior conviction or acquittal of reckless imprudence bars subsequent prosecution for the same quasi-
offense. The lower courts erred in not extending the protection of the Double Jeopardy Clause to the
petitioner. Prosecutions under Article 365 should stem from a single charge, irrespective of the number
or severity of consequences. Only one information should be filed in the same first-level court.

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20. Quizon v. Justice of the Peace, G.R. No. L-6641, July 28, 1955

Facts:

On December 19, 1952, the Chief of Police of Bacolor, Pampanga, filed a criminal complaint against
Francisco Quizon, the petitioner, with the Justice of the Peace Court. Quizon was charged with the crime
of damage to property through reckless imprudence, with the value of the damage amounting to P125.
Quizon filed a motion to quash, arguing that the penalty for the offense exceeds the jurisdiction of the
Justice of the Peace Court. The case was forwarded to the Court of First Instance of Pampanga, but it
was returned for trial on the merits, as the lower court held that it had jurisdiction. Quizon appealed to
the Supreme Court on a question of law.

Issues:

Whether the Justice of the Peace Court has jurisdiction to try the offense of damage to property through
reckless imprudence when the amount of damage is P125.

Whether damage to property through reckless negligence is a variant of malicious mischief and falls
within the jurisdiction of the Justice of the Peace Court.
Ruling:

The Supreme Court held that the Justice of the Peace Court does not have jurisdiction to try the offense
of damage to property through reckless imprudence when the amount of damage is P125. The Court
interpreted the term "malicious mischief" in Section 87, par. 6, of the Judiciary Act to have exclusive
reference to willful and deliberate crimes described in Articles 327 to 331 of the Revised Penal Code.
Damage to property through reckless negligence was deemed not to be a variant of malicious mischief.
The Court emphasized the element of specific malice required for malicious mischief, which is not
present in cases of damage caused by negligence. The jurisdiction over the offense was declared to lie
exclusively with the Court of First Instance. The writ of certiorari was granted, and the order of remand
to the Justice of the Peace Court was reversed and set aside.

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21. Bagajo v. Marave, G.R. No. L-33345, November 20, 1978

Facts:

Marcela M. Bagajo, a public school teacher, whipped her student, Wilma Alcantara, with a bamboo stick,
causing linear bruises on Wilma's legs and thighs. Bagajo argued that she acted to discipline Wilma, who
had tripped a classmate.

Issue:

The primary legal issue revolved around whether Bagajo's actions constituted a criminal offense. The
case explored the legality of corporal punishment by teachers in light of relevant laws and regulations.

Ruling:

The Court of First Instance acquitted Bagajo. The majority opinion held that there was no indication of
criminal intent. It justified Bagajo's actions as disciplinary, emphasizing her role as a teacher exercising
authority in loco parentis. The court acknowledged the prohibition on corporal punishment but deemed
Bagajo's actions reasonable given the circumstances. The dissenting opinion disagreed, asserting that
the act of inflicting physical injuries is a felony and that Bagajo's actions contravened explicit
prohibitions on corporal punishment by teachers.

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22. People v. Moreno, G.R. No. 126921, August 28, 1998

Facts:

Jose Moreno y Castor appeals the June 17, 1996 Judgment of the Regional Trial Court of Pasig City,
Branch 165, in Criminal Case No. 101919. Moreno was convicted of rape and sentenced to reclusion
perpetua based on a Complaint filed by Jocelyn Bansagales and her mother, Dolores Bansagales. Jocelyn,
a 26-year-old mentally retarded woman, accused Moreno of having carnal knowledge of her against her
will and consent on September 29, 1993, using force and intimidation. The trial court found Moreno
guilty and sentenced him accordingly.

Issue:

The main issue is whether the conviction of Moreno under Article 335 of the Revised Penal Code for the
rape of a mentally retarded individual is valid, considering that the specific grounds of force and
intimidation were not explicitly stated in the original complaint.

Ruling:

The court affirmed Moreno's conviction under paragraph 1 of Article 335, which covers rape by using
force or intimidation. Although the original complaint did not specify these grounds, the court held that
Jocelyn's testimony clearly established that Moreno used force and intimidation to have carnal
knowledge of her against her will. The court emphasized that the force required is relative and that, in
the case of a mentally retarded victim like Jocelyn, a lesser degree of force might be sufficient.

The court rejected Moreno's argument that Jocelyn's mental condition affected her ability to testify,
citing the absence of evidence indicating her incapacity to perceive events. It also dismissed the claim
that Moreno was unaware of Jocelyn's mental condition, stating that her mental retardation was
apparent, and Moreno, being a neighbor for several years, could not have been unaware.

The court awarded civil indemnity and moral damages, each amounting to P50,000, without the need
for further proof. The decision affirmed Moreno's guilt beyond reasonable doubt and modified the
judgment to include the ordered payments.

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23. U.S. v. Ah Chong, G.R. No. 5272, March 19, 1910

Facts:

Ah Chong, a cook employed at "Officers' quarters, No. 27," Fort McKinley, Rizal Province, was accused of
homicide for fatally stabbing his roommate, Pascual Gualberto. On the night of August 14, 1908, Ah
Chong was awakened by someone attempting to force open the door of the room he shared with
Pascual. Fearing a robbery, Ah Chong, in the darkness, struck out with a kitchen knife, believing he was
defending himself from an intruder. The blow, however, landed on Pascual, who had returned from a
walk with friends and was trying to enter their shared room.

Issue:
The main issue before the court is whether Ah Chong is criminally liable for the death of Pascual
Gualberto. Specifically, the court needs to determine if Ah Chong's actions were justifiable under the
circumstances, considering his mistaken belief about the threat and the use of force in self-defense.

Ruling:

The court ruled in favor of Ah Chong, holding that he is not criminally liable for the death of Pascual
Gualberto. The court acknowledged that Ah Chong's actions were based on a mistaken belief that he
was defending himself from a dangerous intruder. The court emphasized the principle that criminal
liability is generally attached to an evil intent, and since Ah Chong's actions were not driven by criminal
intent but by a genuine, though mistaken, fear for his safety, he could not be held criminally responsible.
The court also highlighted that Ah Chong's mistake was made without negligence or bad faith.

The court, in its ruling, applied the principles of self-defense and the legal concept that ignorance or
mistake of fact, if genuine and without negligence, can excuse criminal liability. The circumstances of the
case, where Ah Chong genuinely believed he was defending himself from a potential threat, aligned with
the legal requirements for self-defense. The court clarified that for criminal liability to exist, there must
be an evil intent, and Ah Chong's actions did not meet this criterion given the circumstances and his
genuine mistaken belief.

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24. People v. Del Rosario, G.R. No. 127755, April 14, 1999

Facts:

Joselito del Rosario, along with co-accused Ernesto Marquez alias "Jun," Virgilio Santos alias "Boy
Santos," and John Doe alias "Dodong," was charged with the special complex crime of Robbery with
Homicide. They were accused of robbing Virginia Bernas, a 66-year-old businesswoman, of P200,000.00
in cash and jewelry and killing her in the process. Del Rosario pleaded not guilty, while Santos and
Dodong remained at large, and Marquez was killed in a police encounter. The prosecution's key witness,
tricycle driver Paul Vincent Alonzo, provided an eyewitness account of the incident.

Issue:

The main issue revolves around Joselito del Rosario's guilt in the crime of Robbery with Homicide. Del
Rosario argues that he acted under irresistible force and was not part of the conspiracy among his co-
accused.

Ruling:

The court, after a careful review, acquits Joselito del Rosario of the crime charged. The court finds that
his claim of acting under irresistible force is substantiated by clear and convincing evidence. The court
disagrees with the trial court's ruling that del Rosario's fear was merely speculative and remote,
emphasizing that the threat he faced was real and imminent.
Regarding the issue of conspiracy, the court concludes that the prosecution failed to establish
conspiracy beyond a reasonable doubt. Mere presence at the scene of the crime is not enough to prove
conspiracy, and del Rosario's actions were explained as being under duress and fear for his safety.

The court also highlights the violation of del Rosario's rights during custodial investigation, as he was not
informed of his rights, leading to inadmissible verbal admissions. Additionally, the court deems del
Rosario's arrest as unlawful since it did not meet the requirements for a warrantless arrest.

In summary, Joselito del Rosario is acquitted of the crime, and his immediate release from confinement
is ordered unless held for some other lawful cause. The court emphasizes that he was a hapless victim
forcibly used by others to perpetrate the crime.

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25. People v. Esmael Gervero, et al., G.R. No. 206725, July 18, 2018

Facts:

The accused Esmael Gervero, Florencio Arbolonio, Danilo Castigador, Celso Solomon and Eduardo Banes,
conspiring and confederating with one another, with deliberate intent and decided purpose to kill,
armed with firearms, they were then provided, through treachery, evident premeditation and superior
strength, did then and there, willfully, unlawfully, and feloniously attack, assault, shoot and hit
Hernando Villegas, Jose Villegas and Benito Basug, Jr. with said firearms inflicting upon said Hernando
Villegas, Jose Villegas and Benito Basug, Jr. numerous gunshot wounds on different parts of their bodies
which caused their deaths immediately thereafter.

On defense, the accused contend that they were given instructions to conduct a patrol against NPA
member. In the order, they are to use coded calling and response. When they notice the people
approaching, they used such coded calling, and instead of answering, victims fired at them, prompting
accused to fire back which resulted in the death of the victims.

Accused now invoke mistake of fact. The court a quo ruled out the defense of mistake of fact noting that
just a few hours before the incident happened, Bañes, Castigador, and two other unidentified CAFGU
members came to the house of Hernando to ask for money, indicating that they knew each other; and
that Gervero was likewise bound by his testimony that he knew Hernando. The Court of Appeals
affirmed the conviction of the accused.

Issue:

Whether the Trial Court erred in not appreciating the defense of mistake of fact.

Ruling:

No. In the context of criminal law, a "mistake of fact" is a misapprehension of a fact which, if true, would
have justified the act or omission which is the subject of the prosecution. Generally, a reasonable
mistake of fact is a defense to a charge of crime where it negates the intent component of the crime. It
may be a defense even if the offense charged requires proof of only general intent. The inquiry is into
the mistaken belief of the defendant, and it does not look at all to the belief or state of mind of any
other person.

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26. Estrada v. Sandiganbayan, G.R. No. 148560, November 2, 2001

Facts:

Petitioner Joseph Ejercito Estrada, the highest-ranking official to be prosecuted under RA 7080 (Plunder
Law), as amended by RA 7659, argues that the law is unconstitutional because it eliminates the mens
rea element in crimes already punishable under the Revised Penal Code (RPC).

Issue:

Is plunder, a crime punishable under a special penal law (RA 7080), mala in se (inherently immoral or
inherently wrong) and does it require the element of mens rea?

Ruling:

Yes. The court held that plunder is a malum in se crime. The legislative declaration in RA 7659 that
classifies plunder as a heinous offense implies its inherent wrongness. The court argues that even
though plunder is punished under a special law, the nature of the acts makes it inherently wrong. The
ruling emphasizes that treating prosecutions for plunder as if they were mere violations of less serious
laws would be absurd, considering the inherent wrongness of the acts constituting plunder

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27. De Guzman v. Subido, G.R. No. L-31683 (120 SCRA 443

Facts:

Ernesto M. de Guzman, appointed as a patrolman, faced disqualification due to admitting violations of

municipal ordinances on jaywalking and cochero seating. The Commissioner of Civil Service invoked
Republic Act No. 4864, citing a "criminal record."

Issue:

Whether violations of municipal ordinances disqualify a qualified person for appointment to the Quezon
City Police Force under Republic Act No. 4864.

Ruling:
The court ruled in favor of De Guzman, stating that not every ordinance violation constitutes a "criminal
record." The commissioner's decision based on admission alone was deemed unreasonable. The court
ordered De Guzman's reinstatement, assuming he met qualifications, along with backpay for the illegal
termination. The lower court's decision was set aside.

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28. Petralba v. Sandiganbayan, G.R. No. 81337, August 16, 1991 (220 SCRA 644)

Facts:

Richard V. Petralba, the petitioner, served as the Officer-in-Charge of the Municipal Treasury of Alcoy
Cebu from October 23, 1979, until March 15, 1981. In an audit conducted 14 months after his
designation, Petralba was found short of P28,107.00, leading to charges of malversation, illegal use of
public funds, and falsification of public documents. Petralba continued his role as Municipal Treasurer
after being granted probation. A subsequent audit covering the period from December 23, 1980, to
March 15, 1981, revealed a shortage of P50,447.06 in his cash and accounts. Vouchers amounting to
P43,468.84 were presented, but only P21,348.87 was allowed, reducing Petralba's accountability to
P29,098.19. The remaining vouchers were disallowed due to lack of administrative approval. On
December 4, 1981, the auditing team sent a letter demanding the turnover of Petralba's cash
accountability. On July 30, 1984, Petralba was charged with malversation of public funds for willfully
misappropriating P29,098.19.

Issue:

Whether Richard V. Petralba is guilty beyond reasonable doubt of the crime of Malversation of Public
Funds under Article 217 of the Revised Penal Code.

Ruling:

The Sandiganbayan found Richard V. Petralba guilty beyond reasonable doubt of Malversation of Public
Funds. The court sentenced him to an indeterminate penalty of six (6) years and one (1) day of prision
mayor, as minimum, to ten (10) years and one (1) day of prision mayor, as maximum. He was also
ordered to pay a fine of P6,978.22, suffer perpetual special disqualification, indemnify the government
in the same amount, and pay the costs. The court appreciated the mitigating circumstance of voluntary
surrender, with no aggravating circumstances proven by the prosecution.

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29. Patulot v. People, G.R. No. 235071, January 7, 2019

Facts:

The accused faced charges for child abuse under Section 10(A) of Republic Act No. 7610 (R.A. 7610) for
intentionally causing physical harm to minors AAA (three years old) and BBB (two months old) by
pouring boiling oil on them.

CCC, the mother, reported the incident, leading to the accused's arrest.
Issues:

Whether the Court of Appeals erred in affirming the accused's conviction under Section 10(A) R.A. 7610
despite the absence of intent to degrade the children's intrinsic worth and dignity.

Ruling:

The petition is denied. R.A. 7610 defines child abuse to include acts causing physical harm that debase
or demean a child's intrinsic worth. The accused's act of pouring boiling oil on the minors constituted
physical abuse. Section 10(A) of R.A. 7610 applies to acts not covered by the Revised Penal Code, and
the court upheld the accused's conviction under this provision. Section 10(A) of R.A. 7610 penalizes acts
of child abuse, cruelty, or exploitation, extending beyond the Revised Penal Code. "Child abuse" involves
intentional physical harm that diminishes a child's intrinsic worth. The court focused on the objective
definition of child abuse rather than the accused's intent.

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

Facts:

Gemma T. Jacinto, along with Anita Busog de Valencia and Jacqueline Capitle, was charged with
Qualified Theft before the RTC of Caloocan City. The charge stemmed from an allegation that the three
accused, all employees of Mega Foam International Inc., conspired to steal a Banco De Oro check worth
₱10,000.00 issued by a customer, Baby Aquino, for purchases made from Mega Foam. The check, given
to Jacinto as the collector of Mega Foam, was deposited in the Land Bank account of Jacqueline Capitle's
husband, Generoso Capitle, without Mega Foam's knowledge. Mega Foam's owner discovered the
irregularity, leading to an entrapment operation where Jacinto and Valencia were arrested while
attempting to receive marked money. The RTC convicted all three accused of Qualified Theft. The CA
modified the decision, acquitting Capitle and reducing Valencia's sentence. Jacinto filed a petition for
review on certiorari.

Issues:

1. Whether Jacinto can be convicted of a crime not charged in the information.

2. Whether a worthless check can be the object of theft.
3. Whether the prosecution proved Jacinto's guilt beyond reasonable doubt.

Ruling:
The Court granted the petition, finding Jacinto guilty of an Impossible Crime as defined in Articles 4(2)
and 59 of the Revised Penal Code. The Court held that the crime of theft is produced upon the taking of
personal property, and in this case, the check had no value as it was subsequently dishonored. Factual
impossibility, due to the check being unfunded and therefore worthless, prevented the crime from being
consummated. The Court emphasized that unlawful taking is deemed complete upon the offender
gaining possession of the thing, even if they have no opportunity to dispose of it. Jacinto was sentenced
to six months of arresto mayor.

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31. People v. Ejercito, G.R. No. 229861, July 2, 2018

Facts:

The appeal involves Francisco Ejercito's challenge to his conviction for rape in 2001. The prosecution
asserted that Ejercito threatened and sexually assaulted a minor, AAA, causing her emotional distress
and drug addiction. Despite Ejercito's claim of a consensual relationship, both the Regional Trial Court
(RTC) and the Court of Appeals (CA) upheld the rape conviction based on AAA's credible testimony.

Issues:

The central question is whether Ejercito's rape conviction should be upheld. Specifically, the court must
determine the applicable law between Article 266-A of the Revised Penal Code (RPC), as amended by
Republic Act No. 8353, and Section 5 (b) of Republic Act No. 7610, both addressing sexual offenses
against minors.

Ruling:

The court rules in favor of upholding Ejercito's rape conviction under Article 266-A of the RPC, as
amended by RA 8353. The court rejects the "focus of evidence" approach used in previous cases and
asserts that RA 8353, being the more recent and comprehensive law on rape, should uniformly apply in
cases of sexual intercourse against minors. Ejercito is sentenced to reclusion perpetua, and the
monetary awards to AAA are affirmed. The court emphasizes that legal interpretation, not the severity
of penalties, determines the applicable law in conflicting situations. The CA's decision is affirmed with
modifications, confirming Ejercito's guilt and the specified penalties and monetary awards.

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32. Cachulogan v. People, G.R. No. 225695, March 21, 2018

Facts:

Ireneo Cahulogan appealed his conviction for Fencing under PD 1612. He was found guilty of buying
stolen Coca-Cola products, allegedly from Loreto Lariosa, without proper documentation. The Court of
Appeals affirmed the Regional Trial Court's decision.
Issue:

The key question was whether Cahulogan's conviction for Fencing was valid.

Ruling:

The Court upheld the conviction, citing evidence of Cahulogan's knowledge or should-have-known status
regarding the stolen goods. The Court modified the penalty, recognizing an incongruence in penalties
and providing an indeterminate sentence of four (4) years, two (2) months, and one (1) day of prision
correccional to fifteen (15) years of reclusion temporal.

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33. People v. Lamahang, G.R. No. 43530, August 3, 1935

Facts:

The defendant, Aurelio Lamahang, appealed a decision from the Court of First Instance of Iloilo.
Lamahang was found guilty of attempted robbery for breaking into a store owned by Tan Yu. Policeman
Jose Tomambing apprehended Lamahang during the act of making an opening in the store's wall. The
lower court sentenced Lamahang to two years and four months of prision correccional, an additional
penalty of ten years and one day of prision mayor for being an habitual delinquent, and ordered him to
pay the costs of the proceeding.

Issue:

The main issue in this case is whether the act of breaking into Tan Yu's store constitutes attempted
robbery or a different offense.

Ruling:

The appellate court ruled that the act committed by Lamahang did not constitute attempted robbery but
rather attempted trespass to a dwelling. The court acknowledged Lamahang's intention to enter the
store using force but found insufficient evidence to establish a clear intent to commit robbery or
another offense. The court held Lamahang guilty of attempted trespass to dwelling, considering the
aggravating circumstances of nighttime and former convictions, as well as the mitigating circumstance of
lack of instruction. The penalty imposed was three months and one day of arresto mayor, with the
accessory penalties and costs.
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34. Baleros, Jr. v. People, G.R. No. 138033, February 22, 2006

FACTS:

 Martina Lourdes Albano (Malou), a medical student at the University of Sto. Tomas, and her
maid Marvilou stayed in Room 307.
 December 12, 10:30 pm: Malou and Marvilou were asleep.
 December 13, 1:00 am: Chito left a fraternity party and arrived at the building wearing specific
attire.
 December 13, 1:50 am: Chito attempted to assault Malou, who fought back, sought help, and
reported the incident.
 December 13, 3:30 pm: Christian and roommates found Chito's bag with incriminating items.
 Chito pleaded NOT Guilty.
 13 witnesses, including Malou, testified.

ISSUE: Whether Chito is guilty of attempted rape.

HELD:

NO. REVERSED and SET ASIDE. ACQUITTING Chito of attempted rape. GUILTY of light coercion,
sentenced to 30 days of arresto menor, and fined P200.00. Rape defined under Article 335 of the
Revised Penal Code. Attempted rape occurs through overt acts indicating intention. Chito, fully clothed,
did not attempt to undress Malou or touch her private parts. Acts constituted unjust vexation,
punishable as light coercion under Article 287. Malou's distress was evident, but it did not prove
attempted rape

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35. Valenzuela v. People, G.R. No. 160188, June 21, 2007

Facts:

The case involves petitioner Aristotel Valenzuela and Jovy Calderon charged with theft. On May 19,
1994, they were seen by security guard Lorenzo Lago stealing detergent from a supermarket. Lago
confronted them, leading to their apprehension and recovery of stolen goods. The trial court convicted
them, and on appeal, Valenzuela argued for a reduced charge of frustrated theft.

Issue:
The central question is whether, based on the facts, the theft should be considered consummated or
frustrated.

Ruling:

The court concluded that, under Article 308 of the Revised Penal Code, theft cannot be in a frustrated
stage. Theft is either attempted or consummated. The critical factor is the unlawful taking, which
completes the crime when the offender gains possession of the stolen item. The inability to freely
dispose of the stolen property does not impact the crime's consummation. The court rejected the
concept of frustrated theft and emphasized legislative intent, stating that recognizing frustrated theft
would require substantial amendments to the law.

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36. People v. Jugueta, G.R. No. 202124, April 5, 2016

Facts:

This case involves an appeal against the Court of Appeals' decision dated January 30, 2012, which
affirmed the Regional Trial Court's judgments. The RTC, Branch 61, Gumaca, Quezon, found Ireneo
Jugueta guilty of Double Murder in Criminal Case No. 7698-G and Multiple Attempted Murder in
Criminal Case No. 7702-G.

Issues:

The accused, Ireneo Jugueta, is charged with Double Murder under Article 248 of the Revised Penal
Code. The alleged crime occurred at about 9:00 o'clock in the evening in Barangay Caridad Ilaya,
Municipality of Atimonan, Province of Quezon, Philippines.

Ruling:

Ireneo Jugueta, armed with a caliber .22 firearm, is accused of willfully, unlawfully, and feloniously
attacking Mary Grace Divina, a minor, aged 13, with the intent to kill. The attack, qualified by treachery
and evident premeditation, resulted in Mary Grace Divina suffering a gunshot wound in the lower
abdomen, right, 2 cm. from the midline.

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37. People v. Orita, G.R. No. 88724, April 3, 1990

Facts:
Ceilito Orita alias Lito was charged with the crime of rape in Criminal Case No. 83-031-B before the
Regional Trial Court, Branch II, Borongan, Eastern Samar. The incident occurred on March 20, 1983, at
about 1:30 AM, inside a boarding house at Victoria St., Poblacion, Borongan, Eastern Samar. The
accused, armed with a Batangas knife, with lewd designs and through threats and intimidation, had
sexual intercourse with Cristina S. Abayan against her will and without her consent.

After being arraigned, the accused pleaded not guilty. The prosecution presented witnesses and
exhibits, while the defense opted not to present evidence and filed a Motion to Dismiss. The trial court,
on August 5, 1985, found the accused guilty of frustrated rape and sentenced him to ten (10) years and
one (1) day to twelve (12) years of imprisonment. The Court of Appeals modified the decision on
December 29, 1988, finding the accused guilty of rape and sentencing him to reclusion perpetua. The
case was forwarded to the Supreme Court upon a resolution issued on January 11, 1989.

Issues:

Whether the trial court erred in disregarding the substantial inconsistencies in the testimonies of the
witnesses.

Whether the trial court erred in declaring that the crime of frustrated rape was committed by the
accused.

Ruling:

The Supreme Court upheld the trial court's decision, finding the accused guilty of consummated rape.
The alleged inconsistencies in testimonies were considered trivial and insufficient to cast doubt on the
witnesses' credibility. The victim's testimony was found to be clear and free from contradiction,
corroborated by the medical examination and the circumstances of the case.

On the issue of frustrated rape, the Supreme Court ruled that rape is consummated upon any
penetration of the female organ, and perfect penetration is not essential. The Court rejected the
concept of frustrated rape, stating that once the offender has carnal knowledge of the victim, all
essential elements of the offense are accomplished, and the felony is consummated. The Court modified
the penalty from death to reclusion perpetua, as it has not imposed the death penalty since February 2,
1987, following the prohibition in the 1987 Constitution.

The decision of the Regional Trial Court was modified, finding the accused guilty of consummated rape
and sentencing him to reclusion perpetua. The accused was also ordered to indemnify the victim in the
amount of P30,000.00.

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38. People v. Quinanola, G.R. No. 126148, May 5, 1999

Facts:
The defense introduced two police officers, PO2 William Beltran and SPO2 Liberato Mascarinas, Jr.,
involved in the crime investigation, and Margarito Villaluna, a suspect early in the police inquiry, who
was often with the accused. PO2 Beltran received a report about the rape incident from barangay
tanods Gilly and George Zozobrado at midnight on March 5, 1994.

Issues:

The court erred in overlooking the inconsistencies in the prosecution witnesses' testimonies, which, if
thoroughly considered, could have altered the outcome.

Ruling:

In the Revised Penal Code, "carnal knowledge" doesn't necessarily require vaginal penetration or hymen
rupture. Rape can be consummated even if the penis enters the labia or lips of the female organ. Partial
penile penetration is as serious as full penetration, and there is no crime of frustrated rape under the
current law.

The court acknowledges that Republic Act No. 7659 retains the provision penalizing an accused who
commits homicide during an attempted or frustrated rape with reclusion perpetua to death. Until
Congress defines frustrated rape, its continued use in the statute book is seen as a persistent lapse in
language.

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39. Ladonga v. People, G.R. No. 141066, February 17, 2005

Facts:

Evangeline Ladonga appeals the Court of Appeals' affirmation of her conviction for violating the
Bouncing Checks Law. She and her spouse obtained loans from a pawnshop, secured by post-dated
checks that bounced, leading to criminal charges.

Issue:

The key issue is whether Evangeline Ladonga, not being a signatory to the checks, can be considered a
co-conspirator and held liable for violating the Bouncing Checks Law.

Ruling:

The Supreme Court grants Ladonga's petition, reversing the Court of Appeals' decision. It holds that the
prosecution failed to prove conspiracy beyond reasonable doubt. Mere presence and knowledge are
insufficient to establish guilt, and Ladonga is acquitted due to the lack of conclusive evidence of her
active participation in the crime. The conviction is set aside, and Ladonga is acquitted of the charges.

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40. Fernan, Jr. v. People, G.R. No. 145927, August 24, 2007

Facts:

The COA Regional Director sought authentication and a report on sub-allotment advisories issued to
highway engineering districts in Cebu. Two sets of LAA’s were received, one authentic and the other
fake, approved by Chief Accountant Rolando Mangubat without authority. The use of fake LAA’s had
been ongoing for years. Accused individuals devised a plan to embezzle funds using fake documents,
leading to their conviction for Estafa through falsification of Public Documents.

Issue:

Whether the Sandiganbayan erred in convicting petitioners as co-conspirators without the prosecution
proving, beyond reasonable doubt, the facts justifying their conviction.

Ruling:

No. The Sandiganbayan correctly ruled on the petitioners' conviction despite the prosecution's failure to
provide direct proof of prior agreement. The court explained that conspiracy can be inferred from the
accused's conduct, showing a common purpose and design. The closeness of personal association and
concurrence of sentiment indicate conspiracy, requiring concerted acts toward a common goal.

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41. Saluday v. People, G.R. No. 215305, April 3, 2018

Facts:

At a military checkpoint, Task Force Davao flagged down a bus, and Security Compliance Assistance Aide
(SCAA) Buco conducted a routine inspection. During the inspection, Buco noticed a small, gray-black
pack bag on the bus, which appeared suspicious. The bag, owned by petitioner Marcelo G. Saluday,
contained an improvised .30 caliber carbine, a magazine with live ammunitions, a cacao-type hand
grenade, and a hunting knife. Saluday was unable to provide proof of authority to carry firearms and
explosives, leading to his immediate arrest.

Issue:
Marcelo G. Saluday challenges the appreciation of evidence by the trial court and the Court of Appeals,
asserting that the warrantless search conducted by Task Force Davao was illegal. He contends that the
evidence obtained during the search should be deemed inadmissible.

Ruling:

The Court ruled against Saluday's claim. Emphasizing the reasonableness of the search, the Court held
that the routine inspection at the military checkpoint was justified for passenger safety. Given the
context of a bus as a vehicle of public transportation with reduced privacy expectations, the Court
deemed the search reasonable and not in violation of constitutional rights. As a result, the warrantless
search was valid, and the items seized from Saluday's bag were considered admissible as evidence.
Saluday's conviction for illegal possession of a high-powered firearm and explosive was upheld.

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42. People v. Raytos, G.R. No. 225623, June 7, 2017

Facts:

During a fiesta, a dance session took place. Versions of the events differed between the defense and the
prosecution. The defense claimed that the victim challenged the respondent to a fight, while the
prosecution alleged that there was no confrontation before the incident.

1. Lorenzo Raytos’ Testimony: Araza, the victim, approached Raytos while dancing with a knife,
and a struggle ensued, resulting in Raytos stabbing the victim multiple times.
2. Dionisio Mado’s Testimony: The victim challenged individuals to a fight, accused Raytos, drew a
knife, and stabbed him, but Raytos managed to disarm and stab the victim.
3. Edgardo Papiona’s Testimony: While dancing with the victim, Papiona witnessed Raytos
stabbing him in the back without any prior argument.
4. Romeo Nacase’s Testimony: Raytos approached the victim from behind while dancing, grabbed
his shirt, and stabbed him in the back without an apparent argument.

Issue:

The central issue revolves around the conflicting testimonies regarding the circumstances leading up to
the stabbing incident. The key question is whether the victim initiated the confrontation by challenging
the respondent to a fight, as the defense contends, or if the stabbing occurred without provocation, as
argued by the prosecution.

Ruling:
The Regional Trial Court (RTC) found Raytos guilty of Murder, qualified by treachery, beyond reasonable
doubt. The Court of Appeals (CA) affirmed the RTC's decision with modifications. The exact nature of the
modifications is not specified in the provided information.

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43. Miranda v. People, G.R. No. 234528, January 23, 2019

Facts:

Miranda faced charges of frustrated homicide for attacking Winardo Pilo with a bolo on August 14, 2011,
in Barangay Binonoan, Infanta, Quezon. Pilo and Damaso, after attending a party, threw stones at
Miranda's house, leading to the assault. Miranda argued self-defense, claiming Pilo's provocation.

Issue:

The primary issue was whether the prosecution established Miranda's guilt for frustrated homicide
beyond reasonable doubt.

Ruling:

The Court of Appeals affirmed Miranda's conviction, denying the petition for lack of merit. While Pilo's
actions did not qualify as unlawful aggression, they were deemed sufficient provocation, mitigating
Miranda's liability.

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44. People v. Olabre, G.R. No. 227421, July 23, 2018

Facts:

Rodolfo Olarbe was charged with murder for the killing of Romeo Arca. The incident occurred on May 7,
2006, at Sitio Pananim, Luisiana, Laguna. The accused pleaded self-defense, claiming that Arca, armed
with a rifle and a bolo, forcibly entered his house, threatened to kill him and his spouse, and attacked
them. Olarbe voluntarily surrendered to the police after the incident. The trial court rejected Olarbe's
self-defense plea, finding that Arca's initial aggression had ceased when Olarbe shot him in the head.
The court disbelieved Olarbe's account of Arca continuing the attack with a bolo.

Issue:
Whether Rodolfo Olarbe is entitled to self-defense and defense of a stranger, justifying his use of force
against Romeo Arca.

Ruling:

The Supreme Court reversed the decisions of the lower courts and acquitted Olarbe. The Court held that
Olarbe established the elements of self-defense and defense of a stranger by clear and convincing
evidence. The Court found that Arca's continuous and persistent unlawful aggression justified Olarbe's
actions, and the means employed were reasonably necessary given the imminent danger. The Court
emphasized the importance of unlawful aggression in justifying self-defense, including both actual or
material aggression and imminent aggression. The Court stressed that reasonable necessity of the
means employed does not require absolute necessity but rational equivalence. It considered the
circumstances, emergency, and imminent danger in evaluating the reasonableness of Olarbe's actions.
The Court acknowledged that a person under imminent threat of harm may not have time for reflection,
and his actions should be judged based on his subjective belief in the necessity to defend himself. The
Supreme Court reversed the decisions of the RTC and CA, acquitted Rodolfo Olarbe on the grounds of
self-defense and defense of a stranger, declared him not civilly liable, and directed his immediate
release from confinement

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45. Ty v. People, G.R. No. 149275, September 27, 2004

Facts:

Petitioner Vicky C. Ty issued seven postdated checks to Manila Doctors’ Hospital, each amounting to
₱30,000. The checks were intended to settle hospital bills for her mother and sister. However, all seven
checks were dishonored due to insufficient funds. Ty claimed she issued the checks under duress,
contending that the hospital mistreated her mother and that she feared for her mother's well-being.
The trial court found Ty guilty of seven counts of violating Batas Pambansa Blg. 222 (B.P. 22), and the
Court of Appeals affirmed the decision with a modification, imposing fines instead of imprisonment.

Issue:

The main issue before the Supreme Court was whether Ty's issuance of bouncing checks was excusable
due to her claims of being forced to issue the checks under duress, acting under uncontrollable fear, and
other defenses.

Ruling:

The Supreme Court denied Ty's petition and affirmed her conviction. The Court rejected Ty's defenses,
emphasizing that the law focuses on the act of issuing a bouncing check. The defense of uncontrollable
fear was not accepted, as it did not meet the requirements for exemption from criminal liability. The
Court upheld the presumption of knowledge of insufficient funds and clarified that B.P. 22 does not
distinguish whether checks were issued in payment of an obligation or as a guarantee. The penalty was
modified, ordering Ty to pay a fine equivalent to double the amount of each dishonored check, with
subsidiary imprisonment in case of insolvency. Ty was also directed to pay Manila Doctors’ Hospital
₱210,000.00, representing the total amount of the dishonored checks. The Court applied Administrative
Circular 12-2000, preferring a fine over imprisonment in appropriate cases.

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46. People v. Gervero, et al., G.R. No. 206752, July 11, 2018 (citing the case of People vs. Oanis)

Facts:

The National Irrigation Administration (NIA) initiated expropriation proceedings for its Lower Agusan
Development Project - Irrigation Component in Butuan City. The affected land parcels, owned by
respondents, were identified for the construction of irrigation canals. After failed negotiations, NIA
based property values on BIR Zonal Valuations. Some landowners agreed to expropriation but proposed
higher values.

Despite the execution of permits and payments for damages to crops, disputes arose over alleged non-
payment for improvements. NIA sought a writ of possession, which was granted by the RTC upon
depositing the full amount based on BIR zonal values.

A Board of Commissioners was appointed to determine fair market values, resulting in a report
submitted in 2006. The RTC adopted the report, awarding just compensation and unrealized income.
The CA affirmed the fair market values but deleted the award for unrealized income. It remanded the
case to the RTC to determine if landowners were fully paid for improvements.

Issue:

Whether the CA erred in affirming the RTC's ruling on just compensation.

Whether there is justification for the CA's remand of the case to the RTC.

Ruling:

The CA's decision on just compensation was affirmed. The Commissioners' Report, utilizing reliable and
actual data for valuation, was upheld. The remand to the RTC was deemed unnecessary. Records
indicated payments made for improvements, and the landowners failed to provide evidence supporting
their claim of underpayment. The Court modified the imposition of 6% interest on just compensation.
Interest of 12% p.a. was imposed from the date of taking (May 7, 2003) until June 30, 2013, and 6% p.a.
from July 1, 2013, until fully paid.
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47. People v. Roy, G.R. No. 2225604, July 23, 2018

Facts:

On June 30, 2010, in Manila, Philippines, Dionesio Roy forcibly had carnal knowledge of a 9-year-old girl,
AAA, by pulling her into a building, covering her mouth, and committing sexual acts against her will.

Issue:

Whether the existence of force, violence, and intimidation is relevant in a statutory rape case where the
victim is under 12 years old and incapable of giving consent.

Ruling:

The Court affirmed the lower courts' decision, finding Dionesio Roy guilty of statutory rape. The issues of
force, violence, and intimidation were considered moot in such cases. The sentence of reclusion
perpetua was upheld, with modifications to exemplary damages, increased to P75,000, and interest on
all damages at 6% per annum until fully paid.

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48. Llave v. People, G.R. No. 166040, April 26, 2006

Facts:

Niel F. Llave, a 12-year-old minor with discernment, allegedly forced himself upon Debbielyn Santos, a 7-
year-old, on September 24, 2002. Debbielyn testified about the incident, describing how she was
assaulted near a vacant house. Niel was convicted and sentenced to six to eight years in prison, with a
fine of Php50,000. The CA affirmed the conviction but modified the sentence to an indeterminate
penalty of two years and four months to eight years and one day. Additionally, Niel was ordered to pay
Php50,000 in moral damages and Php20,000 in exemplary damages.

Issues:

Whether Niel was deprived of the right to a preliminary investigation.

Whether Niel acted with discernment.

Whether the CA-imposed penalty is correct.

Whether Niel is liable for moral damages.

Rulings:

Yes. Niel waived his right to a preliminary investigation by not filing a motion within five days after
learning of the filed Information.

Yes. Niel acted with discernment, considering his behavior during and after the incident and his
academic achievements.

Yes. The CA correctly affirmed the trial court's ruling.

No. Exemplary damages were deleted as no aggravating circumstance was proven.

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49. Dorado v. People, G.R. No. 216671, October 3, 2016

FACTS

Jerwin Dorado filed a Petition for Review on Certiorari seeking to reverse and set aside the August 8,
2014, Decision and the January 29, 2015, Resolution of the Court of Appeals (CA) in CA-G.R. CR No.
33581. The CA affirmed the July 5, 2010, Decision of the Regional Trial Court (RTC), Taguig City, Branch
163, in Criminal Case No. 127784, finding Dorado guilty of frustrated murder. The case involved Dorado
and others charged with frustrated murder and violation of Republic Act No. 7610. Dorado was accused
of shooting Ronald Bonion with a sumpak (improvised shotgun). The RTC found Dorado guilty of
frustrated murder but acquitted him of the RA 7610 charge.

ISSUES

The sole issue raised by Dorado was whether the CA gravely erred in affirming his conviction for the
crime charged.

RULING

Dorado argued that his defenses of alibi and denial should be appreciated, asserting that he was at
home during the incident. The Office of the Solicitor General (OSG) countered that Dorado had the
intent to kill, and his defenses could not overcome positive identification by prosecution witnesses.

The Supreme Court (SC) ruled in favor of Dorado, finding merit in the petition. It emphasized that
Dorado was a minor at the time of the crime, as supported by records. Despite the enactment of the
Juvenile Justice and Welfare Act of 2006 (R.A. No. 9344) after the incident, the SC applied its provisions
retroactively. The SC criticized the lack of attention to Dorado's minority status by the RTC and CA. It
outlined the provisions of R.A. No. 9344, emphasizing that discernment needed to be proven as a
separate circumstance for criminal liability of minors above 15 but below 18 years old. The Prosecution
failed to determine discernment during the trial.

Consequently, Dorado was deemed exempt from criminal liability but not from civil liability. The SC
determined that only frustrated homicide, not frustrated murder, was committed due to the lack of
evidence for evident premeditation. The SC awarded P30,000.00 each for civil indemnity and moral
damages, with legal interest at 6% per annum from the date of finality of the judgment until fully paid.

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50. People v. Sisracon, et al., G.R. No. 226494, February 14, 2018

Facts:

On February 29, 2004, the victim (AAA), a 15-year-old youth group president, was invited by the
appellant Roberto and others to discuss their recently joined organization. Later, they coerced her into a
drinking spree, leading her to an apartment. After consuming alcohol, AAA lost consciousness. When she
regained consciousness, she found herself being assaulted. Subsequently, she identified five individuals,
including Roberto, as the perpetrators.

Issue:

Whether the accused, including Roberto, are guilty of qualified rape against a minor, involving abuse of
superior strength and nighttime.

Ruling:

The trial court found appellants guilty of qualified rape. In Criminal Case No. 7693 and 7694, they were
sentenced to suffer the penalty of Reclusion Perpetua and ordered to indemnify AAA with civil, moral,
and exemplary damages. The court credited the accused for time spent in preventive detention.
Accused John Andrew Valderama, Rex Dandan, Ranil Camaymayan, and Randy Mulog remain at large.
The cases against them are archived pending apprehension.

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51. Nieva v. People, G.R. No. 188751, November 16, 2016

FACTS:

Bonifacio Nieva was charged with the crime of Frustrated Murder in the Regional Trial Court (RTC) of
Malabon, Branch 73. The incident occurred on October 28, 2005, when Nieva allegedly attacked Judy
Ignacio, the president of the Catmon Homeowners Association, with a gun. Nieva was accused of acting
with intent to kill, treachery, and evident premeditation. During the confrontation, Judy was shot in the
leg, but timely medical attention prevented her death. Nieva pleaded not guilty, and the trial ensued.
The prosecution presented witnesses, including Judy, Luna, Raymundo, Dr. Serrano, and PO2 Del Fiero.
The prosecution's version claimed that Nieva, armed with a gun, approached Judy, shouted at her, and
fired the weapon multiple times. The gun jammed, but Judy was wounded. Luna and Raymundo
intervened, disarmed Nieva, and Judy received medical attention. In contrast, Nieva's defense asserted
that the shooting was accidental and occurred during a struggle for the gun.

The RTC, in its October 11, 2007 decision, convicted Nieva of Frustrated Homicide instead of Frustrated
Murder. Nieva appealed to the Court of Appeals (CA), arguing inconsistencies in testimonies and the
applicability of the exempting circumstance of accident. The CA, in its February 25, 2009 decision,
affirmed Nieva's conviction but modified the penalty. Nieva's Motion for Reconsideration was denied on
July 9, 2009.

ISSUE:

Whether the Court of Appeals erred in affirming Nieva's conviction for frustrated homicide.

RULING:

The Supreme Court denied Nieva's petition, upholding the CA's decision. The Court found Nieva's
defenses unconvincing. Minor inconsistencies in testimonies were deemed insufficient to undermine
witness credibility. The court rejected Nieva's claim of accident, as he failed to prove the elements of
accident exemption. Intent to kill was established based on the use of a deadly weapon, the nature of
the wound, and Nieva's conduct during the incident. The CA's decision was affirmed with modifications:
moral damages were decreased, civil indemnity was awarded to Judy Ignacio, and interest was imposed
on all monetary awards. The petition was denied for lack of merit.

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52. People v. Siao, G.R. No. 126021, March 3, 2000

Facts:

Reylan Gimena and Estrella Raymundo (14 years old) are house helpers of Rene Siao. One afternoon in
May 1994, Rene Siao ordered Reylan to pull Estrella into the maids quarter. Siao pointed a gun at Reylan
and ordered him to do sexual acts against Estrella. Siao also pointed a gun at Estrella telling her to suck
his private part. Thereafter, still pointing a gun at both of them, Siao ordered Reylan to have sex with
Estrella using the “dog-style” position. Eventually, Estrella was able to inform the police about what
happened. In the Information filed against Siao, no aggravating circumstances were alleged. During trial,
Estrella and Reylan testified against Siao. In 1996, Siao was convicted for rape as principal by
inducement and was sentenced to suffer the penalty of reclusion perpetua. The court considered the
aggravating circumstance of use of deadly weapon against Siao. Reylan was acquitted.

ISSUE: What are the aggravating circumstances in the case at bar.

HELD: It was proven that Siao used his gun to consummate the crime but under existing jurisprudence,
aggravating circumstances that will change the nature of the crime (or the so called qualifying
circumstances) must be alleged in the Information in order to be appreciated against the accused.
Otherwise, his right to be informed of the nature and cause of accusation against him will be violated.
Had it been alleged, Siao would have been liable for qualified rape. Since there was no allegation, then
he is only liable for simple rape. The penalty for simple rape is reclusion perpetua. On the other hand,
the trial court overlooked the appreciation of the ordinary aggravating circumstance of ignominy. “It has
been held that where the accused in committing the rape used not only the missionary position, i.e.
male superior, female inferior but also the dog position as dogs do, i.e. entry from behind, as was
proven like the crime itself in the instant case, the aggravating circumstance of ignominy attended the
commission thereof.” (People vs Saylan, 130 SCRA 159).

Nevertheless, since the law on rape provides that the penalty for simple rape is reclusion perpetua
regardless of the presence of any aggravating or mitigating circumstances, the penalty of reclusion
perpetua as held by the trial court is sustained.

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53. People v. Datu Karim Masdal, G.R. No. 236594, March 6, 2019

Facts:

Mustafa Sali y Alawaddin, also known as "Tapang/Pang," was charged with violating Sections 5 and 11,
Article II of Republic Act (R.A.) No. 9165, the Comprehensive Dangerous Drugs Act of 2002. The charges
stemmed from a buy-bust operation on June 21, 2010, in Zamboanga City, where Sali allegedly sold a
small quantity of shabu (methamphetamine hydrochloride) to an undercover agent. The prosecution
argued that the chain of custody was maintained during the arrest and seizure of the drugs. Sali claimed
that he was framed, asserting that armed individuals arrived during his son's birthday celebration,
handcuffed him, and demanded money for his release.

Issue:

The central issue in the case revolved around the chain of custody of the seized drugs, as required by
Section 21 of R.A. No. 9165. Specifically, the question was whether the prosecution established a valid
and unbroken chain of custody from the seizure to the presentation of evidence in court.

Ruling:

The Supreme Court, in its ruling, reversed the decisions of the lower courts and acquitted Mustafa Sali
on reasonable doubt. The Court focused on the prosecution's failure to comply with the prescribed
procedures for maintaining the chain of custody. It highlighted that the physical inventory and
photograph of the seized items occurred at the PDEA office, not at the crime scene, without adequate
justification. The absence of Sali's or his representative's signature on the inventory raised doubts about
its authenticity. The Court emphasized the necessity of strict adherence to the chain of custody,
particularly in cases involving minuscule drug quantities. As a result, Sali was ordered to be immediately
released unless held for another lawful cause.

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54. People v. Hirang, G.R. No. 223528, January 11, 2017

FACTS:

Jeffrey Hirang, also known as Jojit and Jojie, was charged with qualified trafficking in persons under
Section 4(a), in relation to Section 6(a) and (c), and Section 3(a), (b), and (c) of Republic Act (R.A.) No.
9208. The charges stemmed from his alleged recruitment, transportation, and provision of minors for
prostitution. The victims, AAA, BBB, CCC, and DDD, were promised a good time, entertainment with
Korean friends, and financial gain. The prosecution's case relied on the victims' testimonies and an
entrapment operation conducted by the International Justice Mission (IJM) in coordination with the
National Bureau of Investigation (NBI).

Hirang's defense claimed he was instigated by IJM agents and denied involvement in sexual trade,
asserting that he was engaged in legitimate business, selling goods like longganisa.

The Regional Trial Court (RTC) found Hirang guilty of qualified trafficking, sentencing him to life
imprisonment and a fine of Two Million Pesos (Php2,000,000.00). The Court of Appeals (CA) affirmed the
RTC decision.

ISSUE:

Whether the prosecution proved beyond reasonable doubt Hirang's guilt for the crime of qualified
trafficking.

Whether Hirang should be acquitted due to the alleged violation of his rights under R.A. No. 7438.

RULING:

The Court affirmed Hirang's conviction for qualified trafficking. The prosecution successfully established
the elements of trafficking, rejecting Hirang's claim of instigation. Any alleged inconsistencies in the
testimonies were deemed minor and inconsequential. The court also held that any defect in Hirang's
arrest was cured by his voluntary participation in the trial without raising the issue.

Hirang was sentenced to life imprisonment and a fine of Two Million Pesos (Php2,000,000.00). Each
victim was awarded ₱500,000.00 as moral damages and ₱100,000.00 as exemplary damages.

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55. People v. SPO4 Ulep, G.R. No. 123547, September 20, 2000

Facts:

Rev. Fr. Dante Martinez entered an oral contract in 1981 to purchase Lot No. 1337-A-3 in Villa Fe
Subdivision from Godofredo and Manuela De la Paz for P15,000.00. Although the lot was still registered
in Claudia De la Paz's name, it had been sold to Manuela De la Paz in 1976. Fr. Martinez, relying on
assurances from the De la Paz family, made a downpayment, secured a building permit, and began
constructing a house on the lot, completing it in October 1981. Fr. Martinez paid the full amount for the
lot in January 1983, but the De la Paz family never delivered the promised Deed of Sale. In 1981, the De
la Paz family sold the same lot to spouses Reynaldo and Susan Veneracion for P150,000.00 with a right
to repurchase. The Veneracions did not take possession of the lots during the redemption period, but
titles were issued to them. In 1986, Fr. Martinez discovered the sale to the Veneracions and demanded
the execution of the Deed of Sale from the De la Paz family. Conflicting decisions arose from an
ejectment case initiated by the Veneracions and an annulment of sale case filed by Fr. Martinez.

Issue:

Whether private respondents Veneracion are buyers in good faith, considering the conflicting claims to
the property.

Ruling:

The Supreme Court ruled that private respondents Veneracion were not buyers in good faith due to
their knowledge of the construction on the lot before the second sale and their failure to inquire about
Fr. Martinez's rights. Consequently, the Court declared the deed of sale between the De la Paz family
and the Veneracions null and void, ordered the De la Paz family to execute a deed of absolute sale in
favor of Fr. Martinez, and instructed the Register of Deeds to cancel the existing title and issue a new
one in Fr. Martinez's name. Additionally, private respondents were directed to pay Fr. Martinez
attorney's fees and the costs of the suit.

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56. Gotis v. People, G.R. No. 157201, September 14, 2007

F acts:

On October 21, 1990, petitioner Nemrod Gotis and his brother Nahom confronted Serafin Gotis's family,
seeking Serafin's whereabouts in a coconut plantation in Barangay Bonga, Bulan, Sorsogon. Nahom,
armed with a bolo, threatened to kill Serafin's daughter during the confrontation. After leaving, Serafin
confronted the brothers. Serafin attempted to hack Nemrod, who retaliated by pursuing and hitting him
several times. Serafin later died from the injuries sustained during the altercation. The trial court found
both brothers guilty of homicide, with the petitioner claiming self-defense.

Issue:

Whether the Court of Appeals (CA) erred in disregarding Nemrod Gotis's claim of self-defense.

Ruling:

The Court partially granted the petition, affirming the conviction but modifying the penalty. The CA's
rejection of self-defense was upheld, as unlawful aggression had ceased when Nemrod pursued Serafin.
However, the Court recognized sufficient provocation as a mitigating circumstance, leading to a
modified sentence of an indeterminate term of four (4) years and two (2) months of prisión correccional
as minimum to ten (10) years of prisión mayor as maximum. Nemrod was ordered to pay Php 50,000 as
indemnity for Serafin's death and Php 3,000 as actual damages.

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57. People v. Rebucan, G.R. No. 182551, July 27, 2011

Facts:

Rosendo Rebucan was charged with double murder for the killings of Felipe Lagera and Ranil Tagpis on
November 6, 2002, in Carigara, Leyte. The accused allegedly armed himself with a long bolo and
attacked the victims with deliberate intent, treachery, and abuse of superior strength. The trial court
found Rebucan guilty of double murder and sentenced him to death.

Issue:

The appellant raised several issues on appeal, including challenges to the court's finding of guilt beyond
reasonable doubt, failure to appreciate mitigating circumstances like immediate vindication and
intoxication, and alleged errors in appreciating aggravating circumstances such as dwelling, abuse of
superior strength, and minority.

Ruling:

The Court of Appeals affirmed the decision but modified the penalty to reclusion perpetua for each
count. The court found that the evidence established the killings with treachery, rejecting the
appellant's claims of error and affirming the trial court's decision. The appeal lacked merit, and the court
upheld the conviction, with certain reductions in monetary awards.

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58. People v. Manzano, Jr., et al., G.R. No. 217974, March 5, 2018

Facts:

Salvador A. Estipona, Jr. faces charges for violating Section 11, Article II of R.A. No. 9165 (Possession of
Dangerous Drugs). On June 15, 2016, he filed a Motion to Allow Plea Bargaining, seeking to change his
plea to guilty for a different offense under R.A. No. 9165. The prosecution expressed openness but cited
Section 23 of R.A. No. 9165, which prohibits plea bargaining. The trial court denied Estipona's motion,
prompting him to file a motion for reconsideration, which was also denied.

Issues:

Whether Section 23 of R.A. No. 9165 is unconstitutional for encroaching on the Supreme Court's rule-
making power.

Ruling:

The Supreme Court's exclusive authority to promulgate rules, including those on constitutional rights
and procedure, was established by the 1987 Constitution. Section 5(5), Article VIII, grants the Court the
power to make rules uniformly applicable to all courts, with no shared authority with the Executive or
Legislative branches. Special court and quasi-judicial body rules remain effective unless disapproved by
the Supreme Court.

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59. Estipona, Jr. v. Hon. Lobrigo and People, G.R. No. 226679

Facts:

Salvador A. Estipona, Jr. is the petitioner challenging the constitutionality of Section 23 of Republic Act
No. 9165, known as the "Comprehensive Dangerous Drugs Act of 2002." The section prohibits plea
bargaining for individuals charged under the act, irrespective of the potential penalty. Estipona faces
charges for the possession of dangerous drugs and sought to enter a plea bargain due to being a first-
time offender with a small quantity of drugs.

Issue:

The main issues raised are whether Section 23 of Republic Act No. 9165 is unconstitutional for violating
the right to equal protection of the law and for encroaching upon the rule-making power of the
Supreme Court.
Ruling:

The Supreme Court ruled in favor of the petitioner, declaring Section 23 unconstitutional. It emphasized
the exclusive rule-making power of the Supreme Court, stating that any prohibition on plea bargaining in
drug cases should be part of procedural rules. The decision underscored the legitimacy and importance
of plea bargaining as a procedural tool, promoting efficiency and justice in the legal system.

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60. People v. Genosa, G.R. No. 135981, January 15, 2004

Facts:

The accused, with intent to kill, with treachery and evident premeditation, did then and there wilfully,
unlawfully and feloniously attack, assault, hit and wound one BEN GENOSA, her legitimate husband,
with the use of a hard-deadly weapon, which the accused had provided herself for the purpose which
caused his death. The Court finds the accused, Marivic Genosa y Isidro, guilty beyond reasonable doubt
of the crime of parricide... after finding treachery as a generic aggravating circumstance and none of
mitigating circumstance, hereby sentences the accused with the penalty of death.She claims that under
the surrounding circumstances, her act of killing her... husband was equivalent to self-defense.

Issues:

Whether the body of the victim should be exhumed and reexamined in order to ascertain the cause of
his death whether the appellant should be examined by qualified psychologists or psychiatrists in order
to determine her state of mind at the time of the killing.

Ruling:

Considering that the appellant has admitted the fact of killing her husband and the acts of hitting his
nape with a metal pipe and of shooting him at the back of his head, the Court believes that exhumation
is unnecessary, if not immaterial, to determine which of said acts actually caused the victim's death.
Prayer sought by appellant for the exhumation of the victim's body cannot be granted.

Wherefore, the Urgent Omnibus Motion of Appellant Marivic Genosa is partly granted.

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61. People v. Nulla, et al., G.R. No. 69346, August 31, 1987

Facts:
In March 1981, Agustin Mecaral and his crew, including Prudencio Nulla, sailed to sell rice. That night,
Nulla attacked Mecaral, tied him with an anchor and trailer, and threw him overboard. They continued
the voyage, eventually being arrested.

Issue:

Whether the appellants are guilty beyond reasonable doubt of robbery with homicide.

Ruling:

The Trial Court convicted Nulla, Cunag, and Jimenez. On appeal, extrajudicial confessions were rejected.
Credible testimony from William Sanchez led to Nulla's conviction for robbery with homicide. Cunag was
an accomplice, sentenced to an indeterminate penalty. Jimenez was acquitted. Costs were apportioned
between Nulla and Cunag.

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62. People v. Magdueño, G.R. No. L-68699, September 22, 1986

Facts:

Accused Hermogenes Magdueno convicted of Murder (qualified by treachery, evident premeditation,

aggravated by price or reward). Magdueno identified by three witnesses as the assailant who shot and
killed City Fiscal Fernando M. Dilig. The prosecution presented an extra-judicial confession wherein
Magdueno admitted to the killing for a price or reward.

Issues:

Validity of the Murder conviction.

Admissibility of the extra-judicial confession.

Ruling:

The Court affirmed the conviction based on positive identification, lack of motive to falsely accuse, and
confession details.

Admissibility upheld; Magdueno properly informed of rights, provided legal counsel, and confession
corroborated.

Lower court decision affirmed, death penalty upheld, excluding insult to public authority as the victim
was the public authority.

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63. People v. Saylan, G.R. No. L-36941, June 29, 1984

Facts:

Rafael Saylan was charged with rape in the Court of First Instance of Misamis Oriental. The complainant,
Eutropia Agno, alleged that on January 23, 1972, Saylan, using a dagger, forced her to remove her panty
and engaged in sexual intercourse against her will. The trial court found Saylan guilty, imposing the
death penalty due to aggravating circumstances: abuse of superior strength, nighttime, uninhabited
place, ignominy, and reiteration.

Issue:

Whether the sexual intercourse was consensual or committed against the will of the complainant.

Whether the trial court correctly considered and applied aggravating circumstances in imposing the
death penalty.

Ruling:

The appellate court affirmed Saylan's guilt but modified the penalty. It rejected the claim of consensual
intercourse, upholding the trial court's findings. The court affirmed the consideration of aggravating
circumstances but reduced the penalty from death to reclusion perpetua. The indemnity to the offended
party was increased to P20,000.00.

The court gave deference to the trial court's credibility assessment, finding the complainant's account
more credible and dismissing Saylan's claim of consensual intercourse. Aggravating circumstances were
upheld, including abuse of superior strength, nocturnity, despoblado, and ignominy. The modification of
the penalty was due to a lack of a sufficient number of votes for the death penalty, reflecting a nuanced
evaluation of the evidence and legal principle

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64. People v. Fontillas, G.R. No. 184177, December 15, 2010

Facts:

Andres Fontillas, also known as "Anding," faced charges of qualified rape under Articles 266-A(1)(c) and
266-B(1) of the Revised Penal Code. The victim, AAA, accused her father of sexually assaulting her
without consent on December 8, 2001. At the time of the incident, AAA was 13 years old, and the crime
was aggravated by the accused's relationship with her. The trial court initially sentenced Andres Fontillas
to death, a decision later modified by the Court of Appeals to reclusion perpetua.
Issue:

Whether the trial court erred in finding the guilt of the accused beyond reasonable doubt.

Whether the trial court erred in convicting the accused despite the alleged weak evidence presented by
the prosecution.

Whether the severe state of intoxication of the accused should have been considered as a mitigating
circumstance.

Ruling:

The Supreme Court affirmed Andres Fontillas' conviction. The Court rejected the accused's arguments,
highlighting the significance of the father's moral ascendancy over his daughter, which could compel
compliance. The Court also considered the threat made by the accused to harm someone if AAA
reported the incident, establishing fear as a relevant factor.

The Court dismissed the accused's claim of extreme intoxication as a mitigating circumstance due to a
lack of evidence proving that the intoxication was not habitual or intentional. The penalties imposed by
the Court of Appeals were affirmed, and the award of exemplary damages was modified to align with
recent jurisprudence. Andres Fontillas was found guilty beyond reasonable doubt of qualified rape,
sentenced to reclusion perpetua without eligibility for parole, and ordered to pay civil indemnity, moral
damages, and exemplary damages to the victim, AAA. The accused was further directed to pay interest
on all damages awarded at the legal rate of Six Percent (6%) per annum from the date of finality of the
judgment. No costs were imposed.

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65. People v. Norona, et al., G.R. No. 132192, March 31, 2000

Facts:

Rudico Mengote died from multiple gunshot wounds, leading to murder charges against the Noroña
brothers, Rogelio and Freddie. On November 17, 1988, Rudico and Alvaro Orosco were driving home.
They encountered the Noroña brothers on a tricycle. Witnesses testified that as the tricycle approached
a bridge, a gunshot was heard, and Rudico fell to the ground. Rogelio shot Rudico multiple times. The
trial revealed conflicting accounts, with Freddie claiming innocence and stating he was sleeping earlier.

Issue:

Whether there was sufficient evidence to establish conspiracy between the Noroña brothers, specifically
if Freddie Noroña actively participated in the homicidal plot with Rogelio.

Ruling:
The appellate court reversed the conviction, acquitting Freddie Noroña.

The court emphasized a lack of positive and convincing evidence for conspiracy. Mere suspicion,
speculation, and association were deemed insufficient to prove conspiracy.

The court questioned the evidence of Freddie's active participation and prior knowledge.

The court considered alternative scenarios, suggesting Freddie might have been unwittingly involved.

Freddie Noroña was ordered released from custody unless detained for another cause.

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66. Quintos v. People, G.R. No. 205298, September 10, 2014

Facts:

On January 15, 2008, Leopoldo Quintos and his brothers Pedro, Rolly, and Lando Quintos, along with
Narciso Buni, were charged with frustrated homicide and homicide. The charges arose from an incident
in Brgy. Laois, Labrador, Pangasinan, where the accused, in conspiracy, attacked Robert M. dela Cruz,
Freddie dela Cruz, and Felomina dela Cruz. The victims sustained severe injuries, and Freddie dela Cruz
eventually succumbed to the attack. The trial court found Pedro, Leopoldo, and Narciso guilty of
homicide and attempted homicide. The Court of Appeals affirmed this decision on appeal.

Issue:

The petitioner raised two primary issues:

The alleged failure of the prosecution to prove guilt beyond reasonable doubt.

The contention that conspiracy was not sufficiently proven, particularly the petitioner's participation in
the attacks on Robert dela Cruz and Felomina dela Cruz.

Ruling:

The Supreme Court dismissed the petition, upholding the Court of Appeals' decision. The Court
emphasized that the review of questions of fact is improper under Rule 45, and the scope of review is
limited to questions of law. The Court highlighted that the trial and appellate courts' uniform findings of
fact deserve respect unless there are compelling reasons to deviate from them. Regarding the
sufficiency of the prosecution's evidence, the Court rejected the petitioner's arguments related to self-
defense, defense of relatives, and the absence of conspiracy. The Court held that the prosecution
witnesses' credible and consistent testimonies, corroborated by medical evidence, supported the guilt of
the accused beyond reasonable doubt. On the existence of conspiracy, the Court ruled that the
petitioner's active involvement in the attack on Freddie dela Cruz was established. The Court held that
conspiracy can be inferred from the acts of the accused, pointing to a joint purpose and design in the
commission of the felony. Ultimately, the Supreme Court affirmed the Court of Appeals' decision,
thereby sustaining the conviction of the petitioner for homicide and attempted homicide.

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67. People v. Bayabos, et al., G.R. No. 171222, February 18, 2015

FACTS:

The case involves the criminal liability of school authorities of the Philippine Merchant Marine Academy
(PMMA) under the Anti-Hazing Law (Republic Act No. 8049). A probationary midshipman, Fernando C.
Balidoy, Jr., died during the mandatory "Indoctrination and Orientation Period" at PMMA. The National
Bureau of Investigation (NBI) recommended criminal charges against certain individuals for hazing,
including school authorities as accomplices. The Sandiganbayan quashed the Information against school
authorities based on the dismissal of the case against the principal accused and alleged deficiencies in
the Information.

ISSUES:

Whether the prosecution of school authorities for accomplice to hazing can proceed despite the
dismissal of the case against the principal accused.

Whether the Information filed against school authorities contains all the material averments for the
prosecution of the crime of accomplice to hazing under the Anti-Hazing Law.

RULING:

The Sandiganbayan erred in dismissing the case against school authorities solely based on the dismissal
of the case against the principal accused. The trial of accomplices can proceed independently if the
commission of the crime is duly established, even if the principal perpetrators are not prosecuted or
acquitted. The Information, however, was quashed because it failed to include essential elements of the
crime, specifically the allegation that the hazing acts were employed as a prerequisite for admission into
the organization (PMMA). The Information lacked crucial details necessary for a successful prosecution.

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68. People vs. Jose, et al., G.R. NO. L-28232, February 6, 1971

Facts:

On June 26, 1967, four principal-accused Jaime Jose, Basilio Pineda Jr., Eduardo Aquino and Rogelio
Cañal conspired together, confederated with and mutually helped one another, then and there, to
willfully, unlawfully and feloniously, with lewd design to forcibly abduct Magdalena “Maggie” dela Riva,
25 years old and single, a movie actress by profession at the time of the incident, where the four
principal accused, by means of force and intimidation using a deadly weapon, have carnal knowledge of
the complainant against her will, and brought her to the Swanky Hotel in Pasay City, and hence
committed the crime of Forcible Abduction with Rape.

Having established the element of conspiracy, the trial court finds the accused guilty beyond reasonable
doubt of the crime of forcible abduction with rape and sentences each of them to the death penalty.

Issue:

Whether or not the trial court made a proper ruling of the case considering the element of conspiracy.

Held:

No, the trial court’s ruling was not proper. The SC ruled that since the element of conspiracy was
present, where the act of one is the act of all, each of the accused is also liable for the crime committed
by each of the other persons who conspired to commit the crime. The SC modified the judgment as
follows: appellants Jaime Jose, Basilio Pineda Jr., and Eduardo Aquino are guilty of the complex crime of
forcible abduction with rape and each and every one of them is likewise convicted of three (3) other
crimes of rape. As a consequence, thereof, each of them is likewise convicted with four death penalties
and to indemnify the victim of the sum of P10,000 in each of the four crimes. The case against Rogelio
Cañal was dismissed only in so far as the criminal liability is concerned due to his death in prison prior to
promulgation of judgment.

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69. People v. Galuga, G.R. No. 221428, February 13, 2019

Facts:

Renato Galuga was charged with rape for an incident that occurred on April 16, 2002. The 12-year-old
victim, AAA, was forcibly taken by Galuga to a closed parlor in the market place, where he threatened
her with a knife, undressed her, and raped her. Witnesses observed Galuga pulling the victim towards
the market place. During the trial, the prosecution presented witnesses, including AAA, her parents, and
other individuals who witnessed the accused pulling the victim. The defense presented Galuga himself,
his live-in partner, and another witness. The Regional Trial Court (RTC) found Galuga guilty of rape and
sentenced him to Reclusion Perpetua, ordering him to pay monetary damages. The Court of Appeals
(CA) affirmed the decision with modifications to the monetary awards.

Issue:
The main issues raised in the appeal to the Supreme Court were whether the trial court erred in
convicting Galuga without proving guilt beyond reasonable doubt and whether it erred in giving full
credence to the prosecution witnesses despite alleged inconsistencies.

Ruling:

The Supreme Court dismissed the appeal and affirmed the decision of the Court of Appeals with
modifications to the monetary awards. The Court held that there was no merit in Galuga's contentions
regarding the alleged inconsistencies in the victim's testimony. It emphasized the credibility of AAA's
straightforward and convincing testimony, highlighting that the trial court and the Court of Appeals had
already accorded great weight to her account.

The Court reiterated the established principles in reviewing rape cases, emphasizing the scrutiny of the
complainant's credibility with extreme caution. The Court also addressed Galuga's plea to withdraw the
appeal, denying it on the grounds that he was ineligible for both parole and probation due to the nature
of the sentence imposed (Reclusion Perpetua). The Supreme Court increased the monetary awards,
ordering Galuga to pay ₱75,000.00 as civil indemnity, ₱75,000.00 as moral damages, and ₱75,000.00 as
exemplary damages, with interest at 6% per annum on all monetary awards from the date of finality of
the decision until fully paid.

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