1 People vs sylvestre

Issue: Whether or not Romana Sylvestre can be convicted as an accomplice to the crime.

Doctrine: Mere passive presence at the scene of another's crime, mere silence and failure to give the
alarm, without evidence of agreement or conspiracy, is not punishable. In this case, the act of Romana
Sylvestre does not constitute the cooperation required by Art. 14 of the Penal Code for complicity in the
commission of the crime.

2 People vs Talingdan

Issue: Whether or not Teresa Domogma is an accessory to Bernardo Bagabag’s murder

Doctrine: Teresa Domogma cannot have the same liability as with her co-appellants. She had no hand in
the actual shooting. But the court is convinced that she knew it was going to be done and did not object.
There is in the record morally convincing proof that she is at the very least an accessory to the offense
committed.Whereas before the actual shooting she was more or less passive in her attitude regarding
the conspiracy, after Bernardo was killed, she became active in her cooperation with her co-appellants.
These acts constitute "concealing or assisting in the escape of the principal in the crime".

3 Manuel vs people

Issue: Whether or not Eduardo Manuel is guilty of bigamy.

Doctrine: The petitioner in this case is charged with bigamy, a felony by dolo (deceit). Article 3,
paragraph 2 of the Revised Penal Code provides that there is deceit when the act is performed with
deliberate intent. Since a felony by dolo is classified as an intentional felony, it is deemed voluntary. For
one to be criminally liable for a felony by dolo, there must be a confluence of both an evil act and an evil
intent (Actus non facit reum, nisi mens sit rea).As a general rule, mistake of fact or good faith of the
accused is a valid defense in a prosecution for a felony by dolo; such defense negates malice or criminal
intent. However, ignorance of the law is not an excuse because everyone is presumed to know the law
(Ignorantia legis neminem excusat).

4 People vs puno

Issue: Whether the accused-appellants committing the felony of kidnapping can be convicted.

Doctrine: There is no showing that appellants had any motive, nurtured prior to the execution or
at the time they committed the wrongful acts against complainant. For the crime of kidnapping
to exist, there must be indubitable proof that the actual intent of the malefactors was to
deprive the offended party of her liberty, and not where such restraint of her freedom of action
was merely an incident in the commission of another offense primarily intended by the
offenders. Criminal intent is necessary in felonies committed by means of dolus or the intent to
do an injury. Although there is general and specific intent provided but not for the charged
felony of kidnapping.
5 People vs delim
Issue: Whether or not the specific intent of the accused is to kidnap or to murder
Doctrine: There was specific intent to murder and not to kidnap. If the primary and ultimate
purpose of the accused is to kill the victim, the incidental deprivation of the victim liberty does
not constitute the felony of kidnapping but is merely a preparatory act to the killing, and hence,
is merged into, or absorbed by, the killing of the victim. Specific intent is a state of mind which
exists where circumstances indicate that an offender actively desired certain criminal
consequences or objectively desired a specific result to follow his act or failure to act. In murder,
the specific intent is to kill the victim. In kidnapping, the specific intent is to deprive the victim of
his/her liberty.

6 US vs Ah Chong
Issue: Whether or not the defendant can be held criminally responsible

Doctrine: Under the circumstances, there is no criminal liability, provided always that the alleged
ignorance or mistake of fact was not due to negligence or bad faith. Since evil intent is in general an
inseparable element in every crime, any such mistake of fact as shows the act committed to have
proceeded from no sort of evil in the mind necessarily relieves the actor from criminal liability. The
defendant acted in good faith, without malice, or criminal intent, in the belief that he was doing no
more than exercising his legitimate right of self-defense; that had the facts been as he believed them to
be he would have been wholly exempt from criminal liability on account of his act; and that he cannot
be said to have been guilty of negligence or recklessness or even carelessness in falling into his mistake
as to the facts, or in the means adopted by him to defend himself from the imminent danger which he
believed threatened his person and his property and the property under his charge.

7 People vs Oanis

Issue: Whether or not Oanis and Galanta can be held responsible for Tecson's death

Doctrine: The appellants found no circumstances whatsoever which would press them to immediate
action. The person in the room being then asleep, appellants had ample time and opportunity to
ascertain his identity without hazard to themselves, and could even effect a bloodless arrest if any
reasonable effort to that end had been made, as the victim was unarmed. Moreover, no unnecessary or
unreasonable force shall be used in making an arrest, and the person arrested shall not be subject to
any greater restraint than is necessary for his detention. A peace officer cannot claim exemption from
criminal liability if he uses unnecessary or unreasonable force in making an arrest.

8 Padilla vs Dizon

Issue: Whether or not the respondent judge is guilty of gross incompetence or gross ignorance of the law
in rendering the decision in question.

Doctrine: The respondent ought to know that malice or deliberate intent is not essential in the offenses
punished by special laws, which are mala prohibita. The respondent ignored the fact that most of the CB
Currency declarations presented by the defense at the trial were declarations belonging to other people
which could not be utilized by the accused to justify his having the foreign exchange in his possession.
Further, CB Circular No. 960 merely provides that for the purpose of establishing the amount of foreign
currency brought in or out of the Philippines, a tourist upon arrival is required to declare any foreign
exchange he is bringing in at the time of his arrival, if the same exceeds the amount of US $3,000 or its
equivalent in other foreign currencies.

9 Magno vs CA

Issue: Whether or not Magno should be punished for the issuance of the checks in question.

Doctrine: BP Blg. 22 is a special statutory law and violations of which are mala prohibita. The court relied
on the rule that in cases of mala prohibita, the only inquiry is whether or not the law had been violated,
proof of criminal intent not being necessary for the conviction of the accused, the acts being prohibited
for reasons of public policy and the defenses of good faith and absence of criminal intent being
unavailing in prosecutions for said offenses. Specifically in this case, the petitioner from the very
beginning never hid the fact that he did not have the funds with which to put up the warranty deposit.
To charge Magno for the refund of a warranty deposit which he did not withdraw as it was not his own
account, it having remained with LS Finance, is to even make him pay an unjust debt since he did not
receive the amount in question. All the while, said amount was in the safekeeping of the financing
company which is managed by the officials and employees of LS Finance.

10 Garcia vs CA

Issue: Whether or not a violation of Section 27(b) of Rep. Act No. 6646, classified under mala in se or
mala prohibita

Doctrine: Generally, mala in se felonies are defined and penalized in the Revised Penal Code, and these
acts complained of are inherently immoral, even if they are punished by a special law. Accordingly,
criminal intent must be clearly established with the other elements of the crime; otherwise, no crime is
committed. On the other hand, in crimes that are mala prohibita, the criminal acts are not inherently
immoral but become punishable only because the law says they are forbidden. Criminal intent is not
necessary where the acts are prohibited for reasons of public policy. The acts prohibited in Section 27(b)
are mala in se because intentionally increasing or decreasing the number of votes received by a
candidate is inherently immoral, since it is done with malice and intent to injure another.

11 Cuenca vs people

Issue: Whether or not appellant is guilty of the crime charged

Doctrine: The convicted appellant herein should be acquitted because he acted with good faith, upon
the ground that the crime of illegal possession of a firearm and ammunition is not malum in se,
but malum prohibitum and that it, accordingly, requires neither malice nor evil purpose or intent. It
should be noted, however, that the Bataan Veterans Security Agency is duly licensed to operate as such.
Consequently, it may legally engage the service of competent persons to discharge the duties of special
watchmen and security guards, and provide them, as such, with the corresponding firearms and
ammunitions. The agency is thus supposed to obtain the license necessary therefor. Had it done so,
there would be no question about the absence of any criminal liability on the part of appellant herein
for the possession of the firearm and ammunition in question, even though the license were not in his
name, but in that of the agency or its owner and operator, Jose Forbes.

12 People vs dela rosa

Issue: Whether or not Dela Rosa is guilty of the crime of illegal possession of firearms

Doctrine: Mere possession is sufficient to convict a person for crimes which are malum prohibitum like
illegal possession of firearms, punished by a special law, in which case good faith and absence of
criminal intent are not valid defenses. However, the kind of possession punishable under PD No. 1866 is
one where the accused possessed a firearm either physically or constructively with animus possidendi or
intention to possess the same. It is not enough that the firearm was found in the person of the accused
who held the same temporarily and casually or for the purpose of surrendering the same.
Admittedly, animus possidendi is a state of mind. As such, what goes on into the mind of an accused, as
his real intent, could be determined solely based on his prior and coetaneous acts and the surrounding
circumstances explaining how the subject firearm came to his possession.

13 Ysidoro vs people

Issue: Whether or not good faith is a valid defense for technical malversation.

Doctrine: Criminal intent is not an element of technical malversation. The law punishes the act of diverting
public property earmarked by law or ordinance for a particular public purpose to another public purpose.
The offense is mala prohibita, meaning that the prohibited act is not inherently immoral but becomes a
criminal offense because positive law forbids its commission based on considerations of public policy,
order, and convenience. It is the commission of an act as defined by the law, and not the character or
effect thereof that determines whether or not the provision has been violated. Hence, malice or criminal
intent is completely irrelevant.

14 People vs pugay
Issue: what are the criminal responsibilities of the accused?
Doctrine: Pugay failed to exercise diligence necessary to avoid every undesirable consequence arising
from any act committed by his companions who at the same time were making fun of the deceased. –
He is GUILTY OF RECKLESS IMPRUDENCE RESULTING TO HOMICIDE. Further, in U.S. vs. Maleza, a man
must use common sense and exercise due reflection in all his acts; it is his duty to be cautious, careful,
and prudent, if not from instinct, then through fear of incurring punishment. He is responsible for such
results as anyone might foresee and for acts which no one would have performed except through
culpable abandon. Otherwise his own person, rights and property, all those of his fellow-beings, would
ever be exposed to all manner of danger and injury.

15 Ivler v. San Pedro

Issue: Whether or not “reckless imprudence” is punishable as a crime in itself

Doctrine: The proposition (inferred from Art. 3 of the Revised Penal Code) that "reckless imprudence" is
not a crime in itself but simply a way of committing it and merely determines a lower degree of criminal
liability is too broad to deserve unqualified assent. There are crimes that by their structure cannot be
committed through imprudence: murder, treason, robbery, malicious mischief, etc. In truth, criminal
negligence in our Revised Penal Code is treated as a mere quasi offense, and dealt with separately from
willful offenses. It is not a mere question of classification or terminology. In intentional crimes, the act
itself is punished; in negligence or imprudence, what is principally penalized is the mental attitude or
condition behind the act, the dangerous recklessness, lack of care or foresight, the imprudencia punible.
16 Villareal vs people

Issue: WON the CA committed grave abuse of discretion when it pronounced Tecson, Ama, Almeda, and
Bantug guilty only of slight physical injuries.

Doctrine: Art. 4(1) of the RPC dictates that the perpetrator shall be liable for the consequences of an act,
even if its result is different from that intended and thus, once a person is found to have committed an
initial felonious act, such as the unlawful infliction of physical injuries that results in the death of the
victim, courts are required to automatically apply the legal framework governing the destruction of life.
From proof that the death of the victim was the cumulative effect of the multiple injuries he suffered,
the only logical conclusion is that criminal responsibility should redound to all those who have been
proven to have directly participated in the infliction of physical injuries on Lenny.

17 People vs guillen

Issue: Whether or not Julio Guillen, is guilty of the crime of murder and multiple attempted murder.

Doctrine: Julio Guillen is liable for all the consequences of his wrongful act; for in accordance with article
4 of the Revised Penal Code, criminal liability is incurred by any person committing felony (delito)
although the wrongful act done be different from that which he intended. In criminal negligence, the
injury caused to another should be unintentional, it being simply the incident of another act performed
without malice. In People vs. Sara, in order that an act may be qualified as imprudence it is necessary
that either malice nor intention to cause injury should intervene; where such intention exists, the act
should qualified by the felony it has produced even though it may not have been the intention of the
actor to cause an evil of such gravity as that produced. And, as held by the Court, a deliberate intent to
do an unlawful act is essentially inconsistent with the idea of reckless imprudence. Where such unlawful
act is willfully done, a mistake in the identity of the intended victim cannot be considered as reckless
imprudence.

18 People vs sabalones

Issue: Whether or not the case is "one of aberratio ictus"

Doctrine: The trial court relied on the concept of aberratio ictus to explain why the appellants staged the
ambush, not to prove that appellants did in fact commit the crimes. The pieces of evidence in this case
sufficiently show that appellants believed that they were suspected of having killed the recently slain
Nabing Velez, and that they expected his group to retaliate against them. Hence, upon the arrival of the
victims' vehicles which they mistook to be carrying the avenging men of Nabing Velez, appellants
opened fire. The Court has held that mistake in the identity of the victim carries the same gravity as
when the accused zeroes in on his intended victim. The case is better characterized as error personae or
mistake in the identity of the victims, rather than aberratio ictus which means mistake in the blow,
characterized by aiming at one but hitting the other due to imprecision in the blow.

19 People vs opero

Issue: Whether or not Article 4, Paragraph 1 of the Revised Penal Code determines the criminal liability
of the accused.
Doctrine: The court finds that Article 4, par. 1 is not applicable to the case at bar because the direct and
intimate connection exists between the robbery and the killing, regardless of which of the two precedes
the other, or whether they are committed at the same time, the crime committed is a special complex
crime of robbery with homicide. Also, it is a settled doctrine that when death supervenes by reason or
on the occasion of the robbery, it is immaterial that the occurrence of death was by mere accident.
What is important and decisive is that death results by reason or on the occasion of the robbery. In the
instant case, the intended victim, not any other person, was the one killed, as a result of an intention to
rob, as in fact appellant and his co-accused, did rob the deceased. In the instant case, the intended
victim, not any other person, was the one killed, as a result of an intention to rob, as in fact appellant
and his co-accused, did rob the deceased.

20 People vs. Albuquerque

Issue: Whether or not appellant’s contention that he did not intend to cause so grave an injury as the
death of the deceased is meritorious.

Doctrine: The trial court found that the appellant did not intend to cause so grave an injury as the death
of the deceased. In his testimony, the appellant emphatically affirmed that he only wanted to inflict a
wound that would leave a permanent scar on the face of the deceased, or one that would compel him
to remain in the hospital for a week or two but never intended to kill him. The act of the appellant in
stabbing the deceased resulted in the fatal wound at the base of his neck, was due solely to the fact
herein before mentioned that appellant did not have control of his right arm on account of paralysis and
the blow, although intended for the face, landed at the base of the neck.

21 Bataclan v. Medina

Issue: Whether or not the proximate cause of the death of Bataclan was the overturning of the bus,
including the passengers left inside.

Doctrine: The proximate cause of the death was the overturning of the bus, and because of the
overturning, it leaked gas which is not unnatural or unexpected. Proximate cause is defined as that
cause which, in a natural and continuous sequence, unbroken by any efficient intervening cause,
produces the injury, and without which the result would not have occurred. Consequently, the
overturning of the bus and not the fire from the lighted torch that burned it, is the event that produced
a continuous natural chain of events, which led to the injury, and held that the bus driver was negligent;
thereby proving the first event to be the proximate cause.

22 Wacoy v. People

Issue: Whether or not the CA correctly found Wacoy and Quibac guilty beyond reasonable doubt of the
crime of Homicide.

Doctrine: In the instant case, there was no tumultuous affray between groups of persons in the course
of which the victim died. On the contrary, the evidence clearly established that there were only two (2)
persons who picked on one defenseless individual and attacked him repeatedly, taking turns in inflicting
punches and kicks on the poor victim. There was no confusion and tumultuous quarrel or affray, nor was
there a reciprocal aggression in that fateful incident. The CA correctly held that the accused-appellants’
act of mauling the victim was the proximate cause of the latter’s death; and as such, they must be held
criminally liable for the crime of Homicide.

23 People v. Iligan

Issue: Whether or not the accused is liable for the victim’s death given that it was due to a vehicular
accident and not the hacking.

Doctrine: Based on the circumstances of the case, the court held that while Iligan’s hacking of Quiñones,
Jr.’s head might not have been the direct cause, it was the proximate cause of the latter’s death.
Proximate legal cause is defined as that acting first and producing the injury, either immediately or by
setting other events in motion, all constituting a natural and continuous chain of events, each having a
close causal connection with its immediate predecessor, the final event in the chain immediately
effecting the injury as a natural and probable result of the cause which first acted, under such
circumstances that the person responsible for the first event should, as an ordinarily prudent and
intelligent person, have reasonable ground to expect at the moment of his act or default that an injury
to some person might probably result therefrom. In other words, the sequence of events from Iligan’s
assault on him to the time Quiñones, Jr. was run over by a vehicle is, considering the very short span of
time between them, one unbroken chain of events. Having triggered such events, Iligan cannot escape
liability.

24 Urbano v. Intermediate Appellate Court

Issue: Whether or not the wound inflicted by Urbano to Javier may be considered as the proximate
cause of the latter’s death.

Doctrine: The wound inflicted by Urbano cannot be considered as the proximate cause of Javier’s death.
The Court defined proximate cause as “that cause which, in natural and continuous sequence, unbroken
by any efficient intervening cause, produces the injury, and without which the result would not have
occurred.” In this case, the death of the victim must be the direct, natural, and logical consequence of
the wounds inflicted upon him by the accused. Urbano is only liable for the physical injuries inflicted to
Javier through the wound on the right palm of his hand. The Court took into account the incubation of
tetanus toxin to the wound, and medical evidence indicated that the victim’s wound was affected with
tetanus.

25 People v. Abarca

Issue: Whether or not Article 247 of the Revised Penal Code defining death inflicted under exceptional
circumstances may be applied in this case dissolving the criminal liability of the accused for the murder
of the deceased

Doctrine: The provision applies in the instant case. Article 247 prescribes the following elements: (1)
that a legally married person surprises his spouse in the act of committing sexual intercourse with
another person; and (2) that he kills any of them or both of them in the act or immediately thereafter.
The Revised Penal Code, in requiring that the accused "shall kill any of them or both of them . . .
immediately" after surprising his spouse in the act of intercourse, does not say that he should commit
the killing instantly thereafter. It only requires that the death caused be the proximate result of the
outrage overwhelming the accused after chancing upon his spouse in the basest act of infidelity. But the
killing should have been actually motivated by the same blind impulse, and must not have been
influenced by external factors; it must be the direct by-product of the accused's rage.

26 Intod v. CA

Issue: Whether or not Article 4 (2) of the Revised Penal Code defining the criminal responsibility of a
party may be applied in the case at bar to modify the liability of the accused from attempted murder to
impossible crime.

Doctrine: Article 4(2) of the RPC qualifies act performed by the offender be unable to produce an
offense against person or property if 1) the commission of the offense is inherently impossible of
accomplishment; or 2) the means employed is either a) inadequate or b) ineffectual. To be the offense
in consideration of being impossible under the clause, the act planned by the offender must be naturally
one that is impossible of achieving having either the 1) legal impossibility, or 2) physical impossibility of
accomplishing the planned act that will constitute such action as an impossible crime.

Legal impossibility applies to circumstances where 1) the motive, desire and expectation is to perform
an act in infringement of the law; 2) there is the intention to execute the physical act; 3) there is the
actual execution of the intended physical act; and 4) the result from the intended act does not amount
to a crime. Factual impossibility on the other hand applies to instances where extrinsic factors unknown
or beyond the control of the offender avert the completion of the intended plan.

27 Jacinto v. People

Issue: Whether or not the crime committed falls the definition of Impossible Crime.

Doctrine: The petitioner is guilty of committing an IMPOSSIBLE CRIME. The requisites of an impossible
crime are: that the Act performed would be an offense against persons or property; that the act was
done with evil intent; that the accomplishment was inherently impossible or the means employed was
either inadequate or ineffectual; and that the act performed should not constitute a violation of another
provision of the Revised Penal Code. There can be no question that as of the time that petitioner took
possession of the check meant for Mega Foam, she had performed all the acts to consummate the crime
of theft, had it not been impossible of accomplishment in this case.