Case Digest Criminal Law

When Leona Laciste endeavored to set fire to the house of Martina Rivera in which 2 children of the latter were sleeping, the two women grappled and Leona Laciste was boloed to death by Martina Rivera. As a result, a criminal prosecution for murder was initiated in the Court of First Instance on La Union.

DECISION OF THE LOWER COURT: Guilty of Homicide.

ISSUE: Whether or not Martina Rivera is guilty of homicide.

DECISION OF THE APPELLATE COURT: Judgment of the Court of First Instance is affirmed, with modification. The accused proceeded beyond the limits of immunity when, after the assailant was out of the house and prostate on the ground, she persisted in wounding her no less than fourteen times.

People of the Philippines vs Juan Alabas GR No. 14218-B February 15, 1956

FACTS: On September 29, 1952, Pantaleon Garcia, a municipal jail detainee informed the chief of police that Juan Abalas was holding an unlicensed firearm. Thereupon, the chief of police ordered Corporal Silvino Pararuan and Patrolman Juan Lastimosa to proceed to Narvacan. The appellant initially denied having possession of the firearm. However, upon being informed that somebody reported that he had in his possession an unlicensed firearm, the appellant admitted that he was really keeping a firearm given by former barrio lieutenant Pantaleon Garcia. Appellant was later taken to the municipal building, where the appellant expressly and voluntarily admitted that he received a gun from Pantaleon Garcia and then hid it by burying the can containing it. Appellant insists on his acquittal for the sole reason that he delivered the gun to barrio lieutenant Pedro Arenas when he announced “that anyone who is concealing firearms should surrender so that they will not be penalized.” This fact was denied by the prosecution.

DECISION OF THE LOWER COURT: Guilty of Illegal Possession of Firearm.

ISSUE: Whether or not the announcement made by barrio lieutenant Pedro Arenas is enough to exempt the appellant from any criminal liability arising from the possession of the unlicensed firearm and ammunition.

DECISION OF THE APPELLATE COURT: Judgment affirmed and modified since no aggravating circumstance has been alleged nor proved. Good faith invoked by the appellant is immaterial since he is being charged with a statutory crime. Illegal possession of firearm is considered malum prohibitum. Mere unauthorized possession is penalized.

People of the Philippines vs Freddie Brana GR No. L-29210 October 31, 1969

FACTS: On the morning of January 6, 1967, 19-year old Corazon Tabano was found by her mother in their house bleeding from several stab wounds. She was rushed to the hospital, she expired a few minutes after arrival. Freddie Brana was formally charged with murder qualified by evident premeditation and abuse of superior strength, and attended by the aggravating circumstances of disregard to sex and dwelling.

DECISION OF THE LOWER COURT: Guilty of Murder. Appellant was sentenced to death. Hence, the automatic review of the case.

ISSUE: Whether or not the trial court erred in considering the killing to have been qualified by evident premeditation.

DECISION OF THE APPELLATE COURT: Decision of the lower court modified, accused is sentenced to life imprisonment. It must be remembered that to justify a finding of evident premeditation it is not enough that there be a threat on the life of the victim. It must be proved that the accused not only had decided to commit the crime but also that the decision was the result of meditation, calculation and reflection.

People of the Philippines vs Luis B. Toring GR No. L-56358 October 26, 1990

FACTS: In the evening of May 25, 1980, a benefit dance was held in Lapu-lapu City for the last canvassing of votes for the candidates for princesses who would reign at the sitio fiesta. As one of the candidates was the daughter of Samuel Augusto, he and the members of his family attended the affair.

Luis Toring, president of the kwaknit gang, was outside the dancing area which was ringed by benches. Samuel Augusto was stabbed by Luis Toring, as soohn as Maria Catalina Sorono saw the stabbing of Samuel, she shouted for help. Samuel was rushed to the hospital where he died on arrival.

DECISION OF THE LOWER COURT: Guilty of Murder.

ISSUE: Whether or not the appellant acted in defense of his first cousin thereby exonerating him from criminal liability.

DECISION OF THE APPELLATE COURT: Judgment Affirmed. The presence of unlawful aggression on the part of the victim and lack of provocation on the part of Toring notwithstanding, full credence cannot be given, to Toring’s claim of defense of a relative. Rather Toring was motivated by revenge, resentment or evil motive because of a running feud between the victim and the Toring brothers.