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Philippine Supreme Court Case Summaries

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Philippine Supreme Court Case Summaries

Uploaded by

Cecille Diaz
Copyright
© © All Rights Reserved
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Available Formats
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- Ladonga v. People, G.R. No.

141066, 17 February 2005

Facts:
Evangeline and Adronico Ladonga faced criminal charges for violating the Bouncing Checks
Law (B.P. Blg. 22) after issuing three dishonored checks as security for loans from Alfredo
Oculam. The Regional Trial Court of Bohol found both guilty on August 24, 1996. Adronico
opted for probation, while Evangeline appealed to the Court of Appeals, which upheld the
RTC's decision on May 17, 1999. After her motion for reconsideration was denied, Evangeline
petitioned the Supreme Court for review.
Issue:
1. Whether Evangeline Ladonga, who was not the drawer or issuer of the checks, could be
held liable for violations of Batas Pambansa Bilang 22 as a conspirator.
Ruling:
The Supreme Court acquitted Evangeline Ladonga of conspiracy charges under Article 8 of
the RPC, stating that her presence during one check's issuance was insufficient. The ruling
emphasizes the need for clear proof and beyond reasonable doubt conviction.
- People v. Simon, G.R. No. 93028, 29 July 1994

Facts:
Martin Simon y Sunga was convicted of selling marijuana to a NARCOM poseur-buyer in
1988. He denied coercion and alleged framed testimony. Despite his defense, he was
sentenced to life imprisonment, fined, and forfeited the marijuana. Simon challenges the
conviction, evidence admissibility, and frame-up.
Issue:
Whether Simon’s actions constituted a violation of the Dangerous Drugs Act.
Ruling:
The Supreme Court upheld Martin Simon y Sunga's marijuana conviction but reduced his
sentence to six years of prision correccional, following amendments under Republic Act No.
7659. The ruling favored NARCOM operatives' credibility over Simon's unsupported claims
and clarified the application of Indeterminate Sentence Law.
- People v. Sylvestre and Atienza, G.R. No. 35748, 14 December 1931, 56 Phil. 353
Facts:
Romana Silvestre and Martin Atienza lived in Masocol, Paombong, Bulacan, leading to an
adultery complaint. After a settlement, they moved to Santo Niño. In November 1930,
Atienza threatened to burn her son's house in retaliation, causing a fire that destroyed 48
houses.
Issue:
1. Whether the lower court erred in convicting Silvestre as an accomplice in the crime of
arson.
Ruling:
Martin Atienza was convicted of arson, claiming revenge. Romana Silvestre was acquitted
due to lack of evidence, as her passive presence and failure to alarm authorities did not
constitute complicity. This reaffirms liability under Article 14 of the Penal Code.
- People v. Puno, G.R. No. 97471, 17 February 1993, 219 SCRA 85
Facts:
Maria Del Socorro Sarmiento y Mutuc was kidnapped in Quezon City by Isabelo Puno and
Enrique Amurao in 1988. They demanded money and demanded P7,000 and P100,000.
Socorro escaped, but was later charged with kidnapping. Puno and Amurao were convicted
of robbery with extortion, sentencing them to reclusion perpetua.
Issue:
1. Whether the accused-appellants committed kidnapping for ransom under Article 267 of
the Revised Penal Code, a violation of Presidential Decree No. 532, or simple robbery under
Article 294 of the Revised Penal Code.
Ruling:
The Philippine Supreme Court convicted Isabelo Puno and Enrique Amurao of simple
robbery, stating their primary motive was extortion through intimidation, not kidnapping for
ransom. The court imposed an indeterminate sentence of 4 years and 2 months of prision
correccional.

- People v. Delim, G.R. No. 142773, 28 January 2003


Facts:
Modesto Delim, his wife Rita, son Randy, and two grandchildren were attacked by Marlon,
Robert, and Ronald Delim at their home in Pangasinan. The Delims restrained and gagged
Modesto, while Rita and Randy remained unharmed. Modesto's body was found in Paldit,
Sison, with multiple stab and gunshot wounds. Suspects were identified, but Robert and
Manuel Delim evaded capture.
Issue:
1. Whether the prosecution proved the guilt of Marlon, Ronald, and Leon Delim beyond
reasonable doubt for the crime of murder.
Ruling:
The Supreme Court ruled that the attackers' primary intent was to kill Modesto, with
kidnapping being incidental. The use of deadly weapons and numerous wounds confirmed
the intent to kill. The court concluded a clear conspiracy, with the alibis of Marlon, Ronald,
and Leon rejected due to weak evidence. The facts supported a conviction for homicide.

- US v. Ah Chong, G.R. No. 5272, 19 March 1910, 15 Phil. 488


Facts:
Ah Chong, a cook in Fort McKinley, Rizal, killed his roommate Pascual Gualberto in 1908
after he threatened to kill him if they entered their room. Fear of robberies intensified,
prompting him to keep a knife under his pillow. Ah Chong was found guilty of simple
homicide and sentenced to six years and one day of presidio mayor.
Issue:
1. Whether Ah Chong can be held criminally liable given his belief that he was acting in self-
defense based on a mistaken apprehension of the facts.
Ruling:
The Supreme Court ruled that criminal liability doesn't apply if a defendant believes self-
defense is necessary, not based on negligence or bad faith. Ah Chong's conviction was
overturned, as his actions were based on a reasonable mistake of fact, and he was not at
fault.

- People v. Oanis, G.R. No. 47722, 27 July 1943, 74 Phil. 257


Facts:
In 1938, Captain Godofredo Monsod and his team, including Chief of Police Antonio Z. Oanis
and Corporal Alberto Galanta, were sent to capture escaped convict Anselmo Balagtas in
Cabanatuan. They mistakenly shot Balagtas, who died from multiple gunshot wounds. The
trial court convicted them of homicide through reckless imprudence, but they appealed to
the Supreme Court of the Philippines.
Issue:
1. Whether or not the defendants acted within the scope of their official duties when they
killed Serapio Tecson.
Ruling:
The Supreme Court ruled that the defendants were not acting within their official duties
when they killed Serapio Tecson, resulting in homicide through reckless imprudence. The
doctrine of honest mistake of fact was not applied, and the defendants were found guilty of
murder, qualifying the act with alevosia (treachery). They were ordered to indemnify the
victim's heirs.
- Padilla v. Dizon, AC No. 3086, 23 February 1988, 158 SCRA 127
Facts:
In 1987, Commissioner of Customs Alexander Padilla filed an administrative complaint
against Judge Baltazar R. Dizon for an erroneous acquittal in a case involving Lo Chi Fai,
claiming gross incompetence and ignorance of the law. Dizon defended his decision, arguing
it was grounded in justice and fundamental principles. The Supreme Court will determine the
issue.
Issue:
1. Whether Judge Dizon was guilty of gross incompetence or ignorance of the law in
acquitting Lo Chi Fai.
Ruling:
The Supreme Court convicted Judge Baltazar R. Dizon of gross incompetence, gross
ignorance of the law, and grave misconduct. The court emphasized that offenses under
special laws are classified as mala prohibita, and Dizon's insistence on proving intent led to
an unjust acquittal. The court ordered Dizon's dismissal, forfeiture of retirement benefits,
and prohibition from reinstatement.

- Magno v. CA, G.R. No. 96132, 26 June 1992, 210 SCRA 475
Facts:
In 1983, Oriel Magno struggled to finance a car repair shop due to financial difficulties. He
sought financing through LS Finance and Management Corporation, which required a 30%
warranty deposit. Teng arranged for an advance from Joey Gomez, who then handed the
check to Teng without Magno's knowledge. Teng later reclaimed the equipment, and Magno
was convicted under the Bouncing Checks Law. The Court of Appeals upheld the conviction,
prompting Magno to petition the Supreme Court for review.
Issue:
1) Whether the issuance of the postdated checks constituted violations of B.P. 22,
considering the nature and purpose of the “warranty deposit.”
Ruling:
The Supreme Court acquitted Magno of charges, reversing the Court of Appeals' decision.
Magno was wrongly charged for refunding a "warranty deposit" since the leasing agreement
remained a loan for equipment with ongoing rental payments, and he didn't personally
benefit from the funds, which stayed with the financing company.
- Garcia v. CA, G.R. No. 157171, 14 March 2006, 484 SCRA 617
Facts:
Arsenia B. Garcia was convicted of conspiring to decrease votes for senatorial candidate
Aquilino Q. Pimentel, Jr. in the 1995 elections. She was sentenced to six years in prison, but
appealed to the Court of Appeals, which increased the minimum penalty.
Issue:
1. Whether a violation of Section 27(b) of Republic Act No. 6646 is classified under mala in
se or mala prohibita.

Ruling:
The Supreme Court upheld the Court of Appeals' decision, denying Garcia's appeal for
intentionally decreasing votes for a senatorial candidate, deemed immoral and carried out
with malice. The court found no evidence of good faith or accidental error, emphasizing the
importance of extraordinary diligence in canvasser board members.

- People v. Pugay, L-74324, 17 November 1988, 167 SCRA 439


Facts:
Fernando Pugay and Benjamin Samson were convicted of murdering Bayani Miranda during
a town fiesta in Rosario, Cavite. Despite pleading not guilty, the prosecution relied on
eyewitness testimony, and the trial court determined they met its burden of proof, leading
to their conviction.
Issue:
1. Whether the trial court erred in utilizing the statements of accused-appellants despite
them not being assisted by counsel during the custodial investigation.
Ruling:
The Supreme Court affirmed the trial court’s decision with modifications, finding that the
eyewitness testimony alone was sufficient for conviction, and the absence of other
eyewitnesses did not indicate suppression of evidence. Eyewitness Gabion’s testimony was
deemed credible and substantial. Pugay was found guilty of homicide through reckless
imprudence, while Samson was guilty of homicide, with adjustments made to their penalties
and indemnities based on the nuances of their actions and the consequences.
- Ivler v. San Pedro, G.R. No. 172716, 17 November 2010.
Facts:
In 2004, Jason Ivler was charged with two criminal cases following a vehicular accident with
Evangeline and Nestor Ponce. He pleaded guilty to the first case and received public
censure. Ivler attempted to quash the second case, but the MeTC rejected it. He then
appealed to the Regional Trial Court, which dismissed the case, citing Ivler's absence.
Issue:
1. Whether Ivler forfeited his standing to seek relief in S.C.A. 2803 by not appearing at the
arraignment in Criminal Case No. 82366.
Ruling:
The Court upheld Ivler's right to maintain his petition in S.C.A. No. 2803 despite his non-
appearance at the arraignment. They ruled that double jeopardy was a valid defense, as
quasi-offenses are singular regardless of consequences, and prosecuting Ivler for the same
reckless act constitutes double jeopardy.

People v. Guillen, L-1477, 18 January 1950, 85 Phil. 307.


Facts:
On March 10, 1947, Julio Guillen attempted to assassinate President Manuel Roxas during a
political rally in Quiapo, Manila. He threw a hand grenade at Roxas, which exploded, injuring
several and resulting in the death of Simeon Varela. Guillen was apprehended by law
enforcement, who attributed his actions to political dissatisfaction.
Issue:
1Was Guillen guilty of murder or was it a lesser crime such as homicide through reckless
imprudence?
Ruling:
The Court convicted Julio Guillen of murder for the death of Simeon Varela, determining his
deliberate actions to cause harm. Guillen's actions were classified as a complex crime,
resulting in multiple grave felonies. The Court applied Article 48, which mandates the
maximum penalty for the most serious felony, and imposed Guillen's death sentence,
ignoring aggravating circumstances like nighttime attacks.

- People v. Adriano, G.R. No. 205228, 15 July 2015


Facts:
On March 13, 2007, an ambush in Malapit, San Isidro, Nueva Ecija resulted in the deaths of
Danilo Cabiedes and Ofelia Bulanan. The assailants, traveling in a Toyota Corolla, were
identified by off-duty police officers. Rolly Adriano y Samson was arrested and charged with
two counts of murder. Adriano presented an alibi, claiming he was in Pampanga at the time,
but the Regional Trial Court found him guilty. The Court of Appeals upheld the decision.
Issue:
1. Whether there are qualifying and aggravating circumstances to convict Adriano for the
crime of murder
Ruling:
Rolly Adriano was identified as a suspect in the ambush that led to the deaths of Danilo
Cabiedes and Ofelia Bulanan, establishing his role in the murders and the qualifying
circumstance of treachery. The court established separate crimes of murder for each victim,
and treachery was applicable even for the unintended victim, Bulanan, due to the
treacherous attack method.

- People v. Sabalones, G.R. No. 123485, 31 August 1998, 294 SCRA 751
Facts:
In 1985, a violent ambush in Talisay, Cebu, resulted in multiple victims being shot by high-
powered firearms. Second Assistant Provincial Prosecutor Juanito M. Gabiana Sr. filed
charges against Sabalones, Beronga, Alegarbes, and Cabanero. The Regional Trial Court
convicted them of murder and frustrated murder, sentencing them to various terms. The
Court of Appeals modified the penalties, imposing reclusion perpetua.
Issue:
1. Were the evidences and witness testimonies credible and sufficient to support the
convictions?
Ruling:
The Supreme Court upheld the trial court's verdict in a murder case, stating that the
witnesses' credibility and evidence were strong. The defense's alibi was deemed insufficient,
and the convictions for murder and frustrated murder were upheld. Treachery was confirmed
as a qualifying circumstance, and penalties were set at reclusion perpetua for murder and
frustrated murder charges.
- People vs. Albuquerque, G.R. No. 38773, 19 December 1933, 59 Phil. 150
Facts:
Gines Alburquerque, a paralytic widower with nine children, lived with his daughter Maria
and daughter Pilar. Pilar had an intimate relationship with Manuel Osma, leading to her
pregnancy and childbirth in 1928. Alburquerque sought Osma's help but failed. In a
confrontation, Osma refused to marry Pilar, leading to Alburquerque's death. He was
charged with homicide and sentenced to eight years and one day of prision mayor.
Issue:
1. Whether Alburquerque acted in legitimate self-defense.
Ruling:
The Supreme Court ruled Alburquerque couldn't claim self-defense due to his aggression,
but recognized mitigating circumstances like lack of intent, voluntary surrender, and
passion, reducing his sentence from reclusion temporal to prision mayor.

- Bataclan v. Medina, L-10126, 22 October 1957, 102 Phil. 181


Facts:
On September 13, 1952, a bus carrying 18 passengers overturned in Cavite, trapping four
inside. The bus's front tire burst, causing the bus to zigzag and overturn into a ditch. The fire
ignited gasoline, causing the passengers to die. Salud Villanueva sued Mariano Medina for
damages, which were awarded in Cavite Court of First Instance.
Issue:
1. Whether Mariano Medina, through his agents, exhibited negligence leading to the
accident and subsequent death of the passengers.
Ruling:
The Supreme Court ruled that the defendant's negligence, including speeding and tire burst,
led to the deaths of two people. The court increased compensatory damages to P6,000,
including moral damages, and raised attorney's fees to P800.
- People v. Iligan, G.R. No. 75369, 26 November 1990
Facts:
On August 4, 1980, Esmeraldo Quiñones Jr. and his friends encountered Fernando Iligan,
Edmundo Asis, and Juan Macandog. After a confrontation, Fernando attacked Quiñones Jr.,
causing fatal head injuries. An autopsy confirmed head trauma, but the accused denied
involvement. The trial court convicted them of murder, sentencing them to reclusion
perpetua.
Issue:
1. Whether Iligan and Asis were guilty of murder, or if Quiñones Jr.’s death was the result of
a vehicular accident.
Ruling:
The Supreme Court ruled that Iligan's hacking of Quiñones Jr. was the proximate cause of his
death, citing errors in identifying treachery and evident premeditation. Edmundo Asis was
not deemed a co-conspirator, and Iligan was held criminally liable for homicide.
- Urbano v. Intermediate Appellate Court, G.R. No. 72964, 7 January 1988
Facts:
In Dagupan City, Philippines, Filomeno Urbano hacked Marcelo Javier, causing a flooded rice
field dispute. Javier sustained a hand injury and developed tetanus, leading to his death.
Despite medical treatment and settlement, Urbano was convicted of homicide, with the case
being elevated to the Supreme Court.
Issue:
1. whether Javier’s development of tetanus and subsequent death were the direct,
natural, and logical consequences of the wounds inflicted by Urban
Ruling:
The Supreme Court ruled that Javier's tetanus was likely contracted closer to his death date,
raising doubts about the hacking incident's proximate cause, and acquitted Urbano, though
he could still face civil liability.
- Intod v. CA, G.R. No. 103119, 21 October 1992, 215 SCRA 52
Facts:
In 1979, Sulpicio Intod and his associates coerced Salvador Mandaya into a plan to kill
Bernardina Palangpangan over a land dispute. They targeted Palangpangan's home, but
Palangpangan was absent. Witnesses identified the perpetrators, and Intod was convicted of
attempted murder. He appealed to the Supreme Court, arguing his actions were an
"impossible crime" due to Palangpangan's absence.
Issue:
1. Whether the absence of the intended victim at the time of the aggression constitutes an
‘impossible crime’ rather than attempted murder.
Ruling:
The Supreme Court, while reviewing the case, distinguished between legal and factual
impossibility as outlined in Article 4(2) of the Revised Penal Code, which addresses
"impossible crimes." The Court ruled that Intod's intended crime was physically impossible
due to the victim's absence, classifying it as an "impossible crime" rather than attempted
murder. Consequently, the Supreme Court modified the prior decision, exonerating Intod of
attempted murder and finding him guilty of an "impossible crime."
- People v. Saladino, L-3634, 30 May 1951, 89 Phil. 807
Facts:
Bartolo Saladino and Anastacio Alejo appealed their murder convictions for Luis Bernabe's
death. They were awakened by Felix Pasion and took Bernabe to Pasion's home for
questioning. Saladino brutally assaulted Bernabe, while Alejo reluctantly participated.
Saladino swore an affidavit claiming Bernabe's death was an escape attempt.
Issue:
Whether or not Saladino and Alejo are liable to the death of Bernabe
Ruling:
Bartolo Saladino is found guilty of torturing and causing the death of Luis Bernabe, with
Anastacio Alejo as an accessory. Although not a principal or accomplice, Alejo was convicted
for attempting to conceal Saladino's crime. He was sentenced to imprisonment ranging from
three to six years and two months. In case of Saladino's insolvency, Alejo must indemnify
the victim's family.

- Jacinto v. People, G.R. No. 162540, 13 July 2009


Facts:
In 1997, Gemma T. Jacinto, a collector for Mega Foam International Inc., was accused of
committing qualified theft with Anita Busog de Valencia and Jacqueline Capitle. The case
arose when Jacinto deposited a bounced check into her brother-in-law's account. They were
arrested and charged with criminal activities. The Regional Trial Court convicted them, and
their sentences were modified on appeal.
Issue:
1. Can the petitioner be convicted of a crime not charged in the Information?
Ruling:
The Supreme Court ruled that a worthless check cannot be the object of theft, as qualified
theft requires the stolen property to have value. The petitioner's actions were considered an
"impossible crime" under the Revised Penal Code, leading to a six-month arresto mayor
sentence.
- US v. Eduave, G.R. No. 12155, 2 February 1917, 36 Phil. 209
Facts:
Protasio Eduave, involved in a relationship with the complainant's mother, was accused of
rape and pregnancy. He attacked her, inflicted a severe gash, and attempted to dispose of
her body.
Issue:
Should Eduave’s actions constitute attempted murder or frustrated murder?
Ruling:
The Supreme Court ruled that Eduave's murder was due to "alevosia" (treachery), as his
sudden attack indicated intent to kill. The court clarified the difference between attempted
and frustrated felonies, determining Eduave's actions as frustrated murder. The penalty was
modified to thirteen years of cadena temporal, affirmed with costs.
- Rivera v. People, G.R. No. 166326, 25 January 2006, 480 SCRA 188
Facts:
In 1999, Esmeraldo, Ismael, and Edgardo Rivera were accused of attempted murder
following an assault on Ruben Rodil. Despite their individual defenses, they were found
guilty of frustrated murder and sentenced to imprisonment. The Rivera brothers appealed to
the Court of Appeals, which modified their conviction to attempted murder and adjusted
penalties.
Issue:
1. Whether the accused had the intent to kill the victim when they attacked him.
Ruling:
The Supreme Court confirmed the intent to kill in a coordinated violent act and the use of a
concrete hollow block, rejecting the Rivera brothers' argument of treachery. The Court also
modified the Riveras' sentence to an indeterminate term of two years of prision correccional
and up to nine years and four months of prision mayor.
- Baleros v. People, G.R. No. 138033, 22 February 2006, 483 SCRA 10
Facts:
In 1991, Martina Lourdes T. Albano was assaulted by Renato Baleros, Jr., who attempted to
rape her. Baleros was found guilty by the RTC of Manila, but appealed to the Court of
Appeals, which upheld the ruling. Baleros then challenged the Supreme Court's findings.
Issue:
whether the CA erred in affirming the RTC’s decision finding Baleros guilty beyond
reasonable doubt of attempted rape.
Ruling:
The Supreme Court acquitted Renato Baleros of attempted rape but found him guilty of light
coercion due to insufficient direct evidence and speculation. Baleros's actions were
questionable, but there was no overt act demonstrating intent to rape.
- Valenzuela v. People, G.R. No. 160188, 21 June 2007
Facts:
Aristotel Valenzuela and Jovy Calderon were charged with theft after stealing detergent from
the Super Sale Club in 1994. They initially pleaded not guilty but later claimed they were
bystanders. Valenzuela was convicted of consummated theft by the Regional Trial Court and
the Court of Appeals.
Issue:
1. Whether the theft committed by Valenzuela should be considered as consummated or
merely frustrated.

Ruling:
Aristotel Valenzuela and Jovy Calderon were charged with theft after stealing detergent from
the Super Sale Club in 1994. They initially pleaded not guilty but later claimed they were
bystanders. Valenzuela was convicted of consummated theft by the Regional Trial Court and
the Court of Appeals.
- People v. Lamahang, L-43530, 3 August 1935, 61 Phil. 703
Facts:
On March 2, 1935, Policeman Jose Tomambing caught Aurelio Lamahang attempting to break
into a store owned by Tan Yu. Lamahang was arrested and charged with attempted robbery.
He was sentenced to two years and four months of prison, plus an additional ten years and
one day of prison mayor. Lamahang appealed the conviction to the Supreme Court.
Issue:
1. Whether the acts committed by Lamahang constituted attempted robbery or another
offense.
Ruling:
The Supreme Court ruled that Aurelio Lamahang's actions were not considered attempted
robbery due to lack of evidence. Instead, he was found guilty of attempted trespass to
dwelling under Article 280 of the Revised Penal Code, despite aggravating factors like
nighttime setting and prior convictions, and a revised penalty of three months and one day
of arresto mayor.
- People v. Borinaga, G.R. No. 33463, 18 December 1930, 55 Phil. 433

Facts:
Harry H. Mooney was hired by Juan Lawaan and Basilio Borinaga to build a fish corral in
Calubian, Leyte. Lawaan attempted to collect payment, but Mooney refused. Borinaga
attacked Mooney, attempting to stab him, but was unsuccessful. Borinaga was prosecuted
for frustrated murder, and his defense was rejected, leading to a 14-year, 8-month, and 1-
day reclusion temporal sentence.
Issue:
whether the facts constituted frustrated murder or merely attempted murder under Article 3
of the Penal Code.
Ruling:
The majority opinion ruled the crime frustrated murder, citing Borinaga's clear intent and
external factors. The dissent argued for attempted murder, citing Borinaga's failure to inflict
any injury and the chair's intervention. They cited cases like U.S. vs. Eduave and People vs.
Mabugat. The dissent argued for independent death prevention.
- People v. Trinidad, G.R. No. 79123-25, 9 January 1989, 169 SCRA 51
Facts:
In 1983, fish dealer Lolito Soriano and his helpers were killed by armed INP officer Emeliano
Trinidad while driving to Bayugan. Trinidad shot Soriano and Laroa in the head, while Tan
escaped and was injured. Trinidad claimed he was in Cagayan de Oro City for his birthday
but was arrested and found guilty of murder and frustration.
Issue:
1. Whether the Witness Tan’s testimony was credible and reliable despite minor
inconsistencies.
Ruling:
The Supreme Court deemed Ricardo Tan's testimony credible and consistent, despite minor
discrepancies. Trinidad's alibi was deemed weak, as it was weaker than Tan's positive
identification and detailed account. The court also classified Tan's violence as attempted
murder, highlighting Trinidad's failure to complete the act due to external factors.
- Martinez v. CA, G.R. No. 168827, 13 April 2007.
Facts:
In 1998, Dean and his wife filed a civil complaint against tricycle driver Benjamin P. Martinez
for spreading rumors about Dean's affair with Elvisa Basallo. Martinez attacked Dean
multiple times, causing serious injuries. After the attack, a criminal complaint for frustrated
murder was filed against Martinez, who claimed self-defense. The trial court convicted
Martinez of frustrated homicide, with the Court of Appeals upholding the conviction.
Issue:
1. Was the testimony of Dean sufficient to prove Martinez’s guilt beyond a reasonable doubt
Ruling:
The Supreme Court ruled that Dean's testimony was credible, and Martinez failed to prove
self-defense. The court found Dean's wounds, Martinez's use of a deadly weapon, and intent
to kill were clear indicators of his intent. The court adjusted the damages awarded, granting
PHP 56,275.48 for medical expenses and additional moral and exemplary damages.
- Mondragon v. People, L-17666, 30 June 1966, 17 SCRA 476
Facts;
On July 11, 1954, Serapion Nacionales was attacked by Isidoro Mondragon in his rice field.
Nacionales retaliated, injuring Mondragon. Mondragon was prosecuted for attempted
homicide and sentenced to an indeterminate prison term. He appealed to the Court of
Appeals, which upheld the CFI's decision, and filed a petition for certiorari with the Supreme
Court.
Issue:
1. Whether Mondragon had the intent to kill, which is a necessary element for convicting
him of attempted homicide.
Ruling:
The Supreme Court found no clear evidence of Mondragon's intent to kill, and based on
the less serious physical injuries sustained by Nacionales, he was sentenced to three
months and fifteen days of arresto mayor.
- People v. Sy Pio, L-5848, 30 April 1954, 94 Phil. 885
Facts:
On September 3, 1949, Sy Pio, also known as Policarpio de la Cruz, shot Jose Sy and
injured witness Tan Siong Kiap. He was apprehended and admitted to the shootings.
During the trial, he expressed resentment towards his victims and claimed Chua Tone
was responsible. The trial court convicted him of frustrated murder, imposing an
indeterminate sentence and ordering him to pay damages to Tan Siong Kiap.
Issue:
1. Whether the trial court erred in not finding that Tan Siong Kiap was accidentally shot
by the same bullet fired at Jose Sy.
Ruling:
The Supreme Court ruled in Sy Pio's case that he intentionally shot Tan Siong Kiap,
dismissing claims of accidental shooting. The court modified the conviction from
frustrated murder to attempted murder, recognizing the victim's escape as not fatal. The
court upheld the lower court's order for indemnification.
- People v. Dio, L-36461, 29 June 1984, 130 SCRA 151
Facts:
Crispulo P. Alega was attacked by Hernando Dio and Danilo Tobias while trying to steal his
Seiko wristwatch. Alega was stabbed, and he died. Dio was arrested and confessed to the
crime. Dio was found guilty of robbery with homicide, sentenced to death, and ordered
indemnity to the victim's heirs.
Issue:
1. Whether the crime committed was robbery with homicide or attempted robbery with
homicide
Ruling:
The court classified the case as attempted robbery with homicide under Article 297 of the
Revised Penal Code. The penalty was adjusted from reclusion temporal to reclusion
perpetua, and Dio was sentencing to 10-20 years of reclusion temporal, with an
indemnity increase to PHP 30,000.
- People v. Salvilla, G.R. No. 86163, 26 April 1990.
Facts:
In 1986, Bienvenido Salvilla, Reynaldo Canasares, Ronaldo Canasares, and Simplicio
Canasares orchestrated a robbery at the New Iloilo Lumber Yard. They held owner
Severino Choco, his daughters Mary and Mimie, and Rodita hostage, demanding more
money. Authorities eventually settled on P50,000.00, but Salvilla appealed, claiming
errors in the adjudication and improper consideration of voluntary surrender.
Issue:
1. Whether the crime committed was consummated robbery or merely attempted robbery.
Ruling:
The court rejected the defense's argument that the robbery was merely attempted, stating
that the severance and control of stolen items constitute completion of the crime. Testimony
showed Severino handed over P20,000.00 and an additional P50,000.00, proving
asportation. The offense was classified as "Robbery with Serious Physical Injuries and
Serious Illegal Detention" under Article 48 of the Revised Penal Code.
- People v. Orita, G.R. No. 88724, 3 April 1990, 184 SCRA 105
Facts:
Ceilito Orita, also known as "Lito," was charged with raping Cristina S. Abayan in 1983. The
Regional Trial Court found him guilty and sentenced him to ten years and one day to twelve
years. Orita appealed, but the Court of Appeals modified the sentence and increased the
indemnity. The Supreme Court upheld Abayan's testimony, recognizing the tender condition
of her vulva as evidence.
Issue:
1. Whether the inconsistencies in the testimonies of the prosecution’s witnesses discredit
their testimonies.
Ruling:
The Court ruled minor discrepancies in testimonies indicate truthfulness, stating Abayan's
testimony supports a clear case of sexual assault. It also ruled that frustrated rape does not
exist under Philippine law, as rape is consummated at penetration.
- People v. Campuhan, G.R. No. 129433, 30 March 2000
Facts:
In 1996, Primo Campuhan claimed he witnessed a rape, but contested Corazon's credibility.
In 1997, he was found guilty, sentenced to death, and ordered to pay damages.
Issue:
1. Whether the Supreme Court should uphold the trial court’s ruling of Campuhan’s guilt for
statutory rape
Ruling:
The Supreme Court ruled Campuhan guilty of attempted rape, replacing the initial death
penalty, after the prosecution failed to prove consummated rape. His sentence was reduced
from 8 years to 14 years, 10 months, and 20 days.
- US v. Valdes, L-14128, 10 December 1918
Facts:
In 1918, Mary Lewin's house was set on fire by a kerosene-soaked sack and rag. Severino
Valdes and Hugo Labarro were arrested, and Valdes initially confessed, but later retracted
his confession. Labarro was dismissed due to insufficient evidence.
Issue:
1. Whether Valdes’ confession at the police station is credible and admissible, considering
his retraction during the trial.
Ruling:
The Supreme Court upheld Valdes' initial confession, despite later denials and
inconsistencies. The act was classified as frustrated arson, as the fire did not spread due to
timely intervention. The court agreed with the lower court, setting a penalty of eight years
and one day of presidio mayor, and ordering Valdes to pay trial costs.
Morales v. People, G.R. No. 240337, 4 January 2022
Facts:
Francis O. Morales was charged with reckless negligence resulting in property damage and
multiple injuries in a vehicular accident in Angeles City. He pleaded not guilty and the case
was contested by Morales, arguing issues with the Traffic Accident Report.
Issue:
1. Whether Morales was negligent in causing the vehicular accident resulting in damage
to property and physical injuries
Ruling:
The Supreme Court upheld Morales's conviction for reckless imprudence, modifying the
penalty based on the "Ivler Doctrine" and the severity of the consequences, including minor
physical injuries and property damage, with temperate damages applied.
- People v. Kalalo, G.R. No. 39303-05, 17 March 1934, 59 Phil. 715
Facts:
Marcelo Kalalo and Isabela Holgado were involved in land disputes before October 1, 1932.
On October 1, violence escalated, leading to Arcadio and Marcelino dying. The appellants
were convicted of murder and frustrated murder, later reduced to discharge of firearms.
Issue:
Whether the appellants’ actions constituted murder due to abuse of superior strength or
were merely homicide.
Ruling:
The Supreme Court reclassified the appellants' murder conviction to homicide due to similar
armedness, rejected self-defense claims, and upheld the attempted homicide charge. The
appellants received 14 years, 8 months, and 1 day of reclusion temporal.

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