People vs.

Mariano recalled the events that transpired if he was not in his right senses when
he committed the crime.
Facts:  The testimony of the accused that he was prompted to rape the victim
 MARIO MARIANO Y ALEJANDRO alias Negro of the crime of Rape with because he was not in his right senses inasmuch as he was an addict is no
Homicide. defense at all. Drug addiction is punishable by law. Nobody should profit
 November 11, 1976, in the City of Manila, the said accused wilfully, therefrom.
unlawfully and feloniously and by means of force, violence and  There is no question that the death of the victim was brought about by
intimidation, to wit: by then and there pinning down one LUNINGNING the rape committed by the accused-appellant. That he did not intend to
MAPOLA Y DIWATA. kin her was of no moment. A person who performs a criminal act is
 Diwata was a minor, six years of age, the accused succeeded in having responsible for all the consequences of said act regardless of his intention.
carnal knowledge with her and as a result thereof she suffered traumatic  The testimonies of Dr. Luis Larion a prosecution witness, and Dr. Angelo
laceration of the vagina as well as traumatic injuries on the head causing Singian, a defense witness, established beyond doubt that the death of
profuse hemorrhages and other injuries which are necessarily fatal and the victim was due to profused hemorrhage brought about by the
which were the direct cause of her death thereafter. laceration of the vagina caused by a stiffened male organ or by the
 The accused, assisted by his counsel de oficio, manifested his desire to insertion of a hard blunt object.
enter a plea of guilty to the offense charged.  The extrajudicial confession of the accused is fully corroborated by proof
 Juanita Mapola declared that the victim, Luningning Mapola who was her of corpus delicti. Hence, said extra-judicial confession is sufficient to
6-year old adopted child, she found Luningning on the following after she support conviction.
was missing in an uninhabited house in Fernandez Street, Tondo, Manila,  The decision appealed from is hereby affirmed.
already dead with the dress rolled up to her abdomen, without panty, and
her eyes swollen with blood having oozed from the left eye US v BROBST
 Santiago Vargas, a patrolman, testified on his investigation of the case in Related Provisions:
the process of which, the accused gave his written confession voluntarily. At the time or the case:
 Angelo Singian, Medico Legal Section, WPD, MPF who declared that the Penal Code
death of the victim, luningning, was due to the laceration of the vagina Art 4. Any person voluntarily committing a crime or misdemeanor shall incur
caused by a stiffened male organ or by the insertion of a hard blunt object criminal liability, even though the wrongful act committed be different from that
t out of proportion to the size of the vagina and that the traumatic head which he intended to commit.
injury was only contributory to the cause of death.
 Cesar Villanueva declared that on November 11, 197 6 at. 3:00 o'clock in SUMMARY:
the afternoon, he saw the accused walking unsteadily and when the Brobst and Mann are owners of a mine. Mann fired Saldivar, calling him a thief and
witness asked the accused why, the latter answered that he took was a disturbance and warned him to never come back. A few days later, Saldivar
something but without saying what it was. came back to the mine with 3 others looking for employment. Upon seeing him,
 The trial court concluded from the evidence that the accused really Brobst ordered him to leave to which Saldivar merely grinned. Brobst struck Saldivar
committed the offense charged. with a powerful blow with his closed fist just over the ribs. Saldivar left and died as
Issue: WON the accused is guilty of the crime beyond reasonable doubt. he reached the door to the house. The trial court held Brobst guilty of homicide.
Held: Yes. Brobst appealed. SC upheld judgement of conviction
 It is to be noted that independent of the plea of guilty of the accused, ISSUES:
there is sufficient evidence to convict the accused-appellant beyond 1. WoN Brobst is guilty of homicide even if there was no intent to kill
reasonable doubt. He executed an extrajudicial confession the regularity 2. WoN there was still doubt that the cause of death of was the single blow of
of which was never assailed. The extra-judicial confession shows that he Brobst
gave coherent answer to the questions propounded to him. Moreover, the FACTS:
accused re-enacted the commission of the crime. He could not have 1. Brobst and Mann engaged in work on a mine and gave employment to the
people of Masbate
2. Mann discharged Saldivar because he was a thief and warned him never to set back. She also testified that without any medical intervention, the burns would
foot on the premises again have caused death
3. July 10, 1907 – Saldivar, with 3 others, went to the mine to look for work, was
ordered to leave by Brobst and was then struck with a blow - Napola died on Aug 25 1966. Death certificate indicated burn as the cause
4. Saldivar staggered and went to the direction of his sister’s house 200 yards away of death.
but died as he reached the door to the house.
- During the trial, the prosecutors failed to present the detention prisoners
5. Brobst claims that he had a right to eject the deceased from the mining property
who saw the burning of Napola as witnesses as well as the wife of the deceased
and that he merely pushed lightly, as proved by the body
with no external marks of Violence. He had not intended to kill Saldivar and did not - Nevertheless, Ural was convicted of murder, was sentenced to reclusion
intend to do him any physical injury. perpetua and was ordered to pay for costs
6. Dagadap and Yotiga, bystanders at the time, testified that the blow was indeed
hard. ISSUE: Whether the evidence of the prosecution was sufficient to prove his guilt
7. The trial court held Brobst guilty of homicide and sentenced him to 6 years and 1 beyond reasonable doubt.
day of prision mayor
8. Brobst appealed the decision Held: TC did not err in convicting Ural for murder.

- Ural had his own version of the story. According to him he heard a scream
HOLDING:
for help from Napola whose shirt was in flames when found by him, he removed
1. Defendant asserts that he only exercised his authority to eject the deceased.
the shirt, but did not summon the doctor because he thought that the burns were
However, the court ruled that his violence was far in excess of such authority. Even
not serious.
if the accused did not intend to kill, there can be no doubt that by striking Saldivar,
he intended to do him some injury. One is not relieved from criminal liability for o SC: this statement cannot prevail over the testimony of Alberio
the natural consequences of one's illegal acts, merely because one does not
intend to produce such consequences. o This statement does not prove that he was not the one who burned
2. The deceased was in apparent good health; after receiving the blow immediately Napola, at most this could only mean that he was alarmed by the consequences of
thereafter, started up the short trail to his sister's house and he died as he reach his evil act
the door. "In the absence of evidence of any intervening cause, we think there can
be no reasonable doubt that his death resulted from the blow." - Ural assailed the credibility of Alberio as a witness, saying that he was not
listed as a prosecution witness and that he was convicted of murder in the past
RULING:
Judgment of conviction by the trial court is affirmed. o Wouldn’t preclude him from being a credible witness.

o Since there was no police investigation (accused a police officer), the

THE PEOPLE OF THE PHILIPPINES (PLAINTIFF-APPELLEE) VS. DOMINGO URAL investigation that ensued was done by a special counsel of the fiscal’s office. A
(ACCUSED-APPELLANT) GR No.: L-30801 possible explanation of alberio not being listed at first.
FACTS: o The statements of the witnesses for the defense were not inconsistent
- Alberio went to the municipal building and saw Ural, a policeman inside with that of Alberio’s.
the jail where he was boxing prisoner Napola (who was imprisoned for being
Therefore, there is no reason to not believe in Alberio’s testimony.a
drunk). When Napola fell to the ground he kicked him and poured some liquid on N
and then ignited N’s body. - The present case is covered by article 4 (par.1-result greater than what was
intended).
- Dr. Luzonia Bakil who treated the victim, said that he sustained 2nd degree
burns on the arms, neck, left side of the face and one half of the body including the o Aggravating circumstance: art 14(1).
o TC erred in not appreciating the Mitigating circumstance “that the months and fifteen days' arresto mayor, accessory imprisonment, to
offender had no intention to commit so grave a wrong as that committed” indemnify the aggrieved party, Isidro Benter.
 Villanueva is charged "while quarreling with his opponent, Isidro Benter,
No intent to kill but only to maltreat the drunk napola who might have with having suddenly snatched the bolo which the latter was carrying at his
been making a nuisance of himself belt and with it inflicting upon him a wound in the palm of the right hand
that incapacitated the aggrieved party from performing work for more
He realized the fearful consequence of his felonious act, he allowed Napola than thirty days and which rendered the said principal member entirely
to secure medical treatment at the municipal dispensary useless."
- Since the mitigating circumstance offset the aggravating circumstance, TC  Turns out that Villanueva was not Benter's opponent nor was there any
correctly imposed the penalty of reclusion perpetua which is the medium period of quarrel between the two. Neither did Villanueva inflict wound upon
the penalty for murder. Benter. The latter injured himself by an accident arising out of his own act.
 Benter himself testified that while both of them were standing with their
DECISION: TC decision AFFIRMED. arms folded it occurred to Villanueva to take hold of the bolo which
complainant carried at his belt; that the complainant tried to retain it and
US vs. Divino that in doing so he caught it by the blade and cut himself in the palm of the
right hand.
Facts: A girl named Alfonsa, about 13 years of age when the incident happened, was  Upon finding himself injured the complainant left the spot while Villanueva
a servant for Feliciano Divino and his family. Her feet were the focus in this case remained there.
because it is said that Feliciano Divino burned her feet, in a very unorthodox and  act took place on the 5th of July, 1914, and the complaint was not filed
harmful way in a sense, by setting her feet on fire after applying petroleum to it and until the 10th of October, 1914
tying her down to the floor. He argued in the court that when Alfonsa came to their  Benter was able to testify that the wound delayed in healing for more than
home, her body was full of scars and ulcers, and that the ulcer in her body was forty days
cured, through his efforts.  The trial was held on December 8, and then Benter showed a scar in the
right palm that ran from the base of tHe little finger to the first joint of the
Issue: Whether Feliciano Divino can be acquitted because he argued that he acted
index finger. The judge noted that the index finger was stiff and that the
in good faith and did not mean any harm to the girl, except to help her get cured.
man could not extend the ring finger.
Held: Medical arguments were brought in the light of the decision and that a doctor  The principal charge of the accusation, that Villanueva inflicted upon
clearly identified that the scars on Alfonsa’s feet were indeed because of burns and Benter the wound in question, is not proven in the slightest.
that the wounds became worse on account of Feliciano’s efforts to cure them.  The defense prayed for dismissal. The prosecution did not oppose it. But
Certainly it was found certain that the acts of the guilty person do not seem to have the lower court denied the petition.
been intended to cause an evil, but rather as a remedy. However, article 568 or the
Penal Code clearly states that a person that undertakes medical assistance to Issue: WON Villanueva is guilty of lesiones graves by reckless negligence
another person is liable for any injuries resulting from such treatment, and the fact
Held: No. The defendant did not wound Benter. It was the latter who, by his
that he acted in good faith and according to the best of his ability does not relieve
own act in catching hold of the edge of the blade of the bolo, wounded himself.
him from responsibility, although his ignorance may be considered as a mitigating
circumstance. The defendant did not wound, beat, or assault Benter; consequently he cannot
be guilty of the crime of inflicting serious physical injuries, not even by reckless
US v. ANDRES VILLANUEVA
imprudence.
Facts:
The defendant, in taking or attempting to take the bolo from its scabbard,
made not the slightest threat or any indication of striking with it. His action
 This case has come up on appeal from a judgment of the Court of First appears to have been motived by mere curiosity. The accused was acquitted.
Instance of Mindoro, by which Andres Villanueva was sentenced to two