Philippine Supreme Court Case Summaries
Philippine Supreme Court Case Summaries
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.
- 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. 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.
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.