CASE DIGEST

PEOPLE vs. ORIFON

G.R. No. 36173, 25 November 1932

FACTS:

 In 1931, Maria Orifon was sentenced to cadena perpetua for the murder of her father.
 She pleaded guilty on the preliminary investigation but on the arraignment upon the information
filed in the Court of First Instance, she pleaded not guilty.
 The principal evidence against the accused consisted of her confession in her own dialect (Ilocano)
to Mr. Lieutenant Chavez de la Constabularia.
o In a nutshell, it was 2 years ago since Maria Orifon’s father, named Lazaro Orifon, started
fornicating and violating her. She was threatened by her father that is she screams or tells
her mother; he will kill them both. One night, she picked up her father’s bolo (large cutting
tool) and gave his father a cut on the left side of his neck and on the left side of his
abdomen.

ISSUE/S:

 Whether or not the penalty imposed in this case is an excessive penalty.

RULING/S:

 In view of the fact that the penalty of cadena perpetua no longer exists under the Revised Penal
Code, the sentence must be modified to reclusion perpetua with the accessory penalties provided
by law.
 In view of the horrible wrong that Maria Orifon suffered at the hands of her father and the
obviously depressed state of mind and body which she must have suffered when she premediated
the act of madness and revenge for which she is now condemned under the letter of the law to
suffer lifetime imprisonment, YES – the court, submits to the Chief Executive through the
Department of Justice, its sincere opinion that the penalty imposed in this case (and the law does
not permit any lower penalty) is a clearly excessive penalty, having regard to the condition of the
accused and the circumstances which impelled her to commit the crime for which she stands
convicted.

Prepared by Chester Piñon

CASE DIGEST
PEOPLE vs. CANJA
G.R. No. L-2800, May 30, 1950

FACTS:

 Defendant Teopista Canja has been maltreated by her husband Pedro Jongque.
 Apart from beating her, he squandered their money and kept a woman. Per her signed
confession, on the night of 25 May 1948 when the victim came home, he hit the defendant on the
stomach without any reason. After dinner and going out he hit her again and Teopista felt utmost
resentment against him.
 That night she took she got a hammer and a chisel and struck his head and face until he was dead.
 She woke up her eldest daughter Exuperia to help her carry the body to the creek.
 As her defense, Teopista stated that she woke up when a man was strangulating her and to
defend herself grabbed a piece of wood and struck the assailant twice and later on learned that
it was her husband.
 Court of First Instance found her guilty on the basis of her daughter’s testimony against her, her
signed confession and the autopsy report showing that the injuries suffered by the victim can’t
be from two blows.

ISSUE/S:

 Whether or not the penalty imposed on the appellant is in accordance with the law.

RULING/S:

 Yes, appellant must be declared to have feloniously extinguished the life of her husband. He may
have been unworthy. He may have been a rascal and a bully; but that is no excuse for murdering
him. His badness is not even a mitigating circumstance.
 Wherefore, inasmuch as the penalty imposed on appellant is in accordance with the law (Article
246, Revised Penal Code), the appealed judgment is affirmed, with costs.

Prepared by Chester Piñon