US vs Valdez

G.R. No. 16486, March 22, 1921

Facts:
Defendant Gargantel felt slighted to the comments of Valdez on how to
treat him and the others, the former being the one at the helm. For that,
Gargantel, with a huge knife in his hand, moved towards Valdez. Fearing for his
life, Valdez threw himself into the water; alas, he never resurfaced again.
Subsequently, Gargantel was arrested.
Charge of homicide was filed against Gargantel. He argues however that
he only threatened him but not actually hurt him.

Issue: Whether or not Gargantel is guilty of homicide.

Held: Yes, Gargantel is guilty of homicide.

The Court, citing Reg. vs Halliday, if a man creates in another man’s mind
an immediate sense of danger which causes such person to try to escape, and
in so doing he injures himself, the person who creates such a state of mind is
responsible for the injuries which result.
In this case, Valdez reasonably obeyed to his instinct of self-preservation,
given that a clearly offended Gargantel was coming at him with a big knife in
hand. It is only clear that Gargantel should be held for Valdez’ death; he must
rightfully be convicted of homicide.
 US vs Sornito
G.R. No. 1726, March 29, 1905

Facts:
Defendant Sornito, a police officer, felt slighted when victim Hechanova
did not quickly came over when being called upon. For that, he grabbed the
victim by the neck and assaulted him with the butt of his revolver; worse,
another police joined the assault on the victim. As a result, Hechanova died
after eight days.
Consequently, charge of homicide was filed against the police officers.
However, circumstances prove that the officers in fact did not intend to kill the
victim.

Issue: Whether or not defendants are guilty of homicide.

Held:
Yes, defendants are guilty of homicide.
The Court held that the guilty parties are responsible under the law for all
the unlawful acts executed by them in violation of its principles and for all the
consequences of those acts.
In this case, even if it be conceded that they only intend to inflict the
gravest injury possible to the deceased, they are still held for his death, for such
was the necessary consequence of their felonious act; they must rightfully be
convicted for homicide.
 US vs Zamora
G.R. No. 10615, November 16, 1915

Facts:
Victim Pisan was having a seemingly friendly chat with a lamenting but
frustrated defendant Zamora when the latter suddenly pulled a pocket knife
and stabbed the victim. As a result, Pisan died after two days. Subsequently,
Zamora was arrested.
Charge of homicide was filed against Zamora. He contends however that
he only had a pent up anger to deal with, but not so grave as to actually kill
someone to vent such rage.

Issue: Whether or not Zamora is guilty of homicide.

Held:
Yes, Zamora is guilty of homicide.
Old Penal Code states that any person who voluntarily commits a felony
or misdemeanor shall incur criminal liability, although the wrongful act be not
the one he intended.
In this case, although Zamora only wanted to channel his anger in to
someone or something – who was unfortunately Pisan in this case – by injuring
the victim, the latter’s death is necessarily the consequence of Zamora’s
wrongful act; he must rightfully be convicted of homicide.
 People vs Cornel
G.R. No. L-204, May 16, 1947

Facts:
Victim Burac was struck by a bolo in the forehead by defendant Cornel;
worse, the latter threw a stone that furthered injured Burac. The wound inflicted
by the stone was eventually infected, which caused Burac’s death.
Consequently, charge of homicide was filed against Cornel. He argues
however that he should only be held for physical injuries, to which he was
already convicted for, as the wounds he inflicted were non-fatal. If anything,
Burac’s death should be attributed to the lack of the availability of the anti-
tetanus serum for the deceased’s wound.

Issue: Whether or not Cornel is guilty of homicide.

Held:
Yes, Cornel is guilty of homicide.
The Court, citing People vs Borbano (76 Phil. 702), held that a defendant
must of course be held responsible for the natural consequences of his
unlawful act.
In this case, even if Cornel’s inflicted wounds were not fatal in nature, it
must be recalled that the infection which eventually killed Burac would not even
manifest in the first place had he not sustained wounds; such death must
necessarily be the natural consequence of Cornel’s unlawful act. He must
rightfully be convicted of homicide.
 People vs Buhay
GR No. L-1003, October 27, 1947

Facts:
Defendant Basco, in retaliation from the hit he took from victim Dee
Ching Ting, called upon his comrades, including defendant Aguilar, for them to
look for the Chinese; and indeed they found him. As he saw Aguilar unsheathe
his hunting knife, tried to escape, only to be punched by another by Basco.
Nevertheless, the victim was able to reach the dike and then jumped into the
water. Unfortunately, when he tried to climb up from the water to make another
run, he was pushed down until he was dragged down by the current; His body
was found days later
Consequently, charge of homicide was filed against defendants. Basco
for himself argues that he should only be liable for slight physical injuries
because he was only involved on punching Dee Ching Ting and preventing his
rise from the water.

Issue: Whether or not Basco himself is guilty of homicide.

Held:
Yes, Basco is guilty of homicide.
The Court held that defendants committing a wrongful act should also be
liable for the consequence of such acts.
In this case, even if it be conceded that Basco contributed only by
punching and by preventing him to climb up, these acts necessarily are result
of victim’s death; Basco must rightfully be convicted for homicide.
 People vs Quianzon
G.R. No. 42607, September 28, 1935

Facts:
Defendant Quianzon burned victim Aribuabo by the neck, the latter
sustaining a wound; such wound was not fatal. However, Aribuabo, due to the
pain, twiced removed the bandage covering the wound, which was eventually
infected, and finally led to victim’s death.
Charge of homicide was filed against Quianzon. He argues however, that
he should only be held guilty of serious physical injuries because it was
Aribuabo’s fault for infecting his wound.

Issue: Whether or not Quianzon is guilty of homicide.

Held:
Yes, Quianzon is guilty of homicide.
The Court, citing 13 R.C.L., 751, held that the one who inflicts an injury
on another will be held responsible for his death, although it may appear that
the deceased might have recovered if he had taken proper care of himself.
In this case, even if it be conceded that Aribuabo would have properly
recovered had he let his wound as it is, it’s nevertheless true that he would not
have sustained injury at the first place had Quianzon not burned him. He must
rightfully be convicted for homicide.
 U.S. vs Go Chico
G.R. No. 4963, September 15, 1909

Facts:
Immediately after the Philippine–American War, the Philippines, being a
colony of the US, promulgated an Act No. 1696, which penalizes any flag or any
mementos used by the armed rebellion (primarily the Katipunan) against the
US, to be displayed in any way, from public view.
Around the 4th day of August 1908, defendant Go Chico was displaying
several Emilio Aguinaldo–engraved medallions and a flag similar to that used
in the rebellion. He intended those to be up for sale, after he purchased the
questioned possessions in a public sale made by the sheriff of Manila.
Subsequently, Go Chico was charged for the violation of the said Act. He
argues that he had no ill intent on displaying the mementos other than selling
for profit.

Issue: Whether or not Go Chico is guilty of violating Act No. 1696.

Held:
Yes, Go Chico is guilty of violating Act No. 1696.
In Fiedler vs Darrin, a US jurisprudence, the case held that when an act is
promulgated as illegal, intent of the offender is immaterial.
In this case, even if it holds true that Go Chico has no ill intent in
displaying the flag other than selling profit, the Act need not hold account of
defendant’s intent for him to be guilty. It is quite clear that what is being
penalized is not the intent of the person, but the act itself which is declared
illegal.
 People vs Bayona
G.R. No. L-42288, February 16, 1935

Facts:
During the the 1934 elections, the Election Law then enforced declares
that possession of firearms is not allowed within 50 meters of any polling place.
Defendant Bayona, who apparently violated this rule, by being within the
gated area of the polling place (and approximately 27 meters from the polling
place). On the defense of the defendant, he argues that 1) literal construction
of the rule would be absurd as, for example, any uniformed personnel would be
held liable should they happen to pass by the road directly adjacent to the
polling place; and 2) if it should be ruled that he be within such construction, it
was not intention to violate the rule and that he was merely called by a friend
who happens to be within the fenced area of the polling place.

Issue: Whether or not Bayona is guilty of violating the Election Law.

Held:
Yes, Bayona is guilty of violating the Election Law.
In the case of People vs Urdeleon, it was held that the intention of the
Legislature was to prohibit the display of firearms with intention to influence in
any way the free and voluntary exercise of suffrage. Also, according to People
vs Go Chico, in acts mala prohibita or those offenses that arise from special
laws, it is sufficient that the act is intentionally done.
In this case, the gun ban contemplated by the Election Law is only to
those who can be seen brandishing their firearm near the polling place, and not
those who merely pass by within the 50-m limit by law. Furthermore, it is not
immaterial if indeed Bayona had no intent to violate the gun ban; the fact that
he intentionally commit the act of wielding his gun within 50 meters of the
polling place is sufficient for him to be liable.
 People vs Estoista
G.R. No. L-5793, August 27, 1953

Facts:
Republic Act No. 4 provides for penalties in case of illegal possession of
firearms.
Defendant Estoista (Alberto) noticed that there were wild chickens
scratching the palay and corn plants within his family’s plantation. He resolved
to ask the licensed rifle of his father, Estoista (Bruno) to shoot off the chickens.
His father took the rifle, which was licensed to the same (and not Alberto), and
gave it to Alberto, as Bruno noted that his son shoots has always been a better
shooter than him.
Alberto then proceeded to the plantation. Upon firing the rifle, he
unintentionally shot the victim Dima, a family laborer, instead.
A charge of reckless imprudence resulting to homicide and a violation of
Republic Act No. 4 was filed against Alberto. He made appeal; however he only
appealed to the offense penalized by Republic Act No.4. His counsel argues
that in the Case of US vs Samson, carrying a gun by order of the owner does not
constitute illegal possession of a firearm. In lieu of this, Alberto must similarly
be acquitted for he did not intend to possess it for himself, but because of order
by his father.

Issue: Whether or not Alberto is guilty in violation of Republic Act No. 4.

Held:
Yes, Alberto is guilty in violation of Republic No. 4.
Republic Act No. 4 provides penalty for persons illegally possessing of
firearms. Furthermore, in the case of US vs Samson, it was held that
“possession” includes not only intent to own, but also intent to use. Herein
defendant was acquitted for it was proven that intent to use was absent.
In this case, penalty for Republic No. 4 aptly applicable to Alberto’s case
as he was caught in illegal possession of it. Also, his case is not parallel to that
of US vs Samson, as unlike the facts in the cited case, Alberto deliberately used
the rifle and not merely possess it for his father.
 People vs Murray
G.R. No. L-4467, April 30, 1959

Facts:
Victim Murray (George) married defendant Murray (Ester), the latter
already having four children prior to their meeting. The family were living in a
three bedroom house (all of which found on the second floor): the first by the
couples themselves, second are for the younger children, and the third by the
elder children and their maid. The third room is usually open.
Years after, George was having illicit relations with a certain Varga. Ester
has known of this fact, as positively testified by 1) the mother of Varga, 2) Tagle,
the Murray’s family driver, 3) Ester’s daughter Caridad; and 4) Snure and Pier,
friends of the couple. Furthermore, at the death of George, Ester ordered a
certain del Rosario, owner of the funeral where George’s body lies, to close the
coffin. Subsequently, Varga tried to take a glimpse of her dead lover; thus, del
Rosario asked Ester’s permission. Ester refused, remarking that Varga cannot
as “[Varga] was the cause of all this trouble.”
One rainy early morning, Ester resolved to bring his son, who usually
sleeps with Ester herself, to the third room and asked the maid to let his son
sleep beside her. She then proceeded to close the door. Moments after 4 shots
came from the room of the spouses; George was found lying on the bed dead.
Charge of parricide was filed against Ester. She contends the possibility
of a break-in as 1) the window leading to the balcony were wide open, 2) the
scattered clothes which implies that a robber searched through the drawers of
George for valuables. However, the investigating police officer notes the
impossibility of a break in as, 1) all possible entrances on the first floor were
properly locked and grilled 2) no mud stains, which implies a malefactor
climbed up through the balcony on that rainy morning; and 3) the lock from the
window opens from the inside.

Issue: Whether or not Ester is guilty of parricide.

Held:
Yes, Ester is guilty of parricide.
The Court held that, through citations of past cases, where the identity of
a person committing a crime is in dispute, the motive that may have impelled
the commission is very relevant.
 In this case, it may well be established that the illicit relations incite the
jealousy of Ester, as evidenced by the witnesses’ testimonies; these may well
establish the motive on why Ester would kill his husband.
It should also be noted that police notes of the tight security in coming
the residence of the Murray’s and impossibility for the malefactor to come from
the outside, and supporting the claim that the perpetrator came from their
house itself. Finally the closing of the third room’s door, which is not the usual
practice of the household, clearly indicates an attempt to conceal the felonious
act.