CASE TITLE

FACTS

ISSUE

RULING

People vs. Luague and

Alcansare
November 7, 1935
62 SCRA 504

Wife Natividad in the house with 3 children.

Husband Wenceslao gone to grind corn several km away.
Paulino Disuadido came and began to make love to her.
Natividad cant dissuade Paulino and drew and opened a knife and
threatening her with death. In preparing to lie with her,
Paulino leave the knife to the floor and Natividad and
stabbed him in the abdomen. Paulino ran away by jumping
through the window.

WON Natividad is
exempted
from
criminal liability.

Yes, The attempt to rape a woman constitutes an aggression

sufficient to put her in a state of self defense inasmuch as a womans
honor cannot be esteemed as a right as precious, if not more, than
her very existence; and it is evident that a woman who, thus
imperiled, wounds, nay kills the offender, should be afforded
exemption from criminal liability.
Witness devoid probability.
ACQUITTED both accused.

People vs. Dela Cruz

March 30, 1935
61 SCRA 344

In a narrow part of a trail that was dark, after going to a wake, a man
suddenly threw his arms around her from behind, caught hold of her
breasts and kissed her, and seized her in her private parts; she
tried to free herself, but he held her and tried to throw her
down; that when she felt weak and could do nothing more
against the strength of the man, she got a knife from her
pocket, opened it, and stabbed him in defense of her honor.
Man did not say anything, she asked but he did not answer.
She cried for help but no one answered. She scarcely
recognized the face because of darkness. She desisted as
soon as he released her. (Illiterate barrio girl, unable to write her
name, 18 years old)
Avelina Jaurigue cannot endure anymore what the deceased Amado
Capina was doing to her. (Courting her and stalking) One morning,
inside a chapel, the deceased Amado noticed Avelina and went to
the bench where Avelina was sitting, he placed his hand on the
upper right thigh of the defendant and Avelina pulled with
her right hand the fan knife she always brought with her.
Amado seized her right hand but she quickly grabbed the
knife with her left hand and stabbed Amado in the left side
of his neck, 4 and a half inches deep, which was necessarily
mortal. He died a few minutes later.

WON Remedios de la
Cruz is exempted
from criminal liability.

Yes, Whether she did in fact cried for help, as claimed by her, or
failed to do so because of the suddenness with which the deceased
grabbed her and the fright that which it naturally caused, taking into
consideration the circumstances of the case, she is exempt from
criminal liability in the defense of her honor. ACQUITTED.
Mistake of fact

WON Avelina Jaurigue

is exempted from
criminal liability.

Rafael Bumanglag missed 40 bundles of palay which were kept

in his granary, he found them in an enclosed field at a
distance of about 100 meters from his granary. For
ascertaining who had done it, he left the palay and that night
accompanied by 2 others, he waited for the person who
might get it and it turned out to be Guillermo Ribis,
attempted to carry it away with him. The 3 assaulted
the presumed thief with with sticks and cutting and
stabbing weapons. He fell down and died instantly.

WON the accused

acted in self-defense
prior to an unlawful
aggression.

No, she is not exempted from criminal liability because the said
chapel was lighted with electric lights, her father is inside and there
were important people accompanying her. Under the circumstances,
there was and there could be no possibility of her being raped.
The means employed by her in defense on her honor is
evidently excessive. She committed the crime of HOMICIDE.
Arresto Mayor minimm, Prision correctional maximum.
No reasonable means employed.
Consider the location and other circumstances.
No, based on the codefendants, during the fight with the deceased
Ribis, they only beat the latter with sticks, because he unsheathed
the bolo he carried but according to the health officer and municipal
president of Laoag, the bolo worn by the deceased was in its
sheath and hanging from his waist; therefore it cant be
concluded that the deceased even intended to assault his
murderers, it is not reasonable to believe that, before falling
to the ground in a dying condition he succeeded in sheathing
his bolo.

People vs. Jaurigue and

Jaurigue
February 21, 1946
76 SCRA 174

United States vs.

Bumanglag
December 23, 1909
14 SCRA 644

United States vs. Esmedia

October 21, 1910
17 SCRA 260

There was a dispute between the family of Ciriaco Abando and

Gregorio Esmedia, father of the 2 accused relative to the ownership
of land. There was a quarrel between Gregorio and Santiago. The 2
accused arrived on the scene about the time the fight between
Santiago and Gregorio was terminating, and on seeing their father,
Gregorio, lying in the mud and water; fatally wounded and dying,
and honesty believing that Santiago, who was standing at the time,
would inflict other wounds upon their father, they, in his defense,
immediately killed Santiago.

WON the 2 accused

acted in defense of
an immediate relative
and exempted from
criminal liability.

Yes, Under Art. 8, par. 5 of the RPC any person who, in defending his
father against an unlawful attack, while he still honestly believes to
be in great danger, causes death of the attacking party, is exempt
from criminal liability. The 2 accused are exempt for criminal liability
for causing death of Santiago Abando but not for Ciriaco Abando
RECLUSION TEMPORAL.

Ty vs. People
September 27,
2004
439 SCRA 220

Tys mother and sister was confined but not at the same time. Ty
signed the the Acknowledgement of Responsibility receipt for the
admission of the patients. It amounted to P1,075,592.95. Ty executed
a promissory note and post dated checks but dishonored because of
insufficiency of funds. Demand letters were sent but the obligation
remained unpaid. The defense of Ty was that she issued the checks
because of an uncontrollable fear or greater injury. She was
allegedly forced to issue the checks because the hospital would not
release her mother unless the bills were paid at debasing treatment.

WON Ty is justified because

of Uncontrollable Fear.

No, Ty is guilty. For this exempting circumstance to be invoked

successfully the following must concur: 1) existence of an
uncontrollable fear; 2) fear must be real and imminent and 3) the
fear of an injury is greater than or at least equal to that
committed. In the case, Tys fear was not real and imminent. Her
fear that her mothers health might deteriorate due to the
inhumane treatment of the hospital or that her mother
might commit suicide is speculative and not the
uncontrollable fear contemplated by the law. The evil
sought to be avoided is merely expected or anticipated
hence, this defense is not applicable.

People vs.
Beronilla, et al.
February 28, 1955
96 SCRA 566

Appellant Beronilla was appointed Military Mayor operating as guerilla unit in

Abra. He received a copy of a memorandum authorizing them to appoint a
jury of 12 bolomen to try persons accused of treason, espionage and aiding
the enemy. Arsenio Borjal returned to La Paz and Beronilla, pursuant to his
instructions, placed Borjal under custody. In no time charges of espionage,
aiding the enemy and abuse of abuse of authority were filed against Borjal. A
12-man jury was appointed by Beronilla and he was found guilty on all counts
and imposed upon him death penalty. Beronilla ordered the execution of
Borjal and immediately after the execution he reported it to Col. Arnold who,
in reply request to withhold it.

WON the accused men who

executed Arsenio Borjal are
exempted from criminal
liability and acted in order
of a superior.

Yes, where the accused acted upon orders of superior

officers that they, as military subordinates, could not
question, and obeyed in good faith , without being
aware of their illegality, without any fault or negligence
on their part, the act is not accompanied by criminal
intent.
Letter - Jury is illegal

People vs. Bonoan

February 17, 1937
64 SCRA 87

Celestino Bonoan met the now deceased Carlos Guison on Avenida

Rizal near a barber shop. Francisco Beech, who was in the
barbershop, heard the defendant say in Tagalog, I will kill
you. Beech turned around and saw the accused withdrawing
his right hand, which held a knife, from the side of Guison who
said, also in Tagalog, I will pay you. But Bonoan replied
saying that he would kill him and then stabbed him thrice on
the left side. He died two days later.

WON Celestino Bonoan is

exempted from criminal
liability.
WON Celestino Bonoan
proven insane in the time
of the commission of the
crime.

Yes, he is exempted through the exempting circumstance of

insanity. Based on the evidence presented by the defense,
he has been confined in the insane department of the San
Lazaro Hospital in April 1922 and January 1926, suffering
from dementia praecox. All persons suffering from dementia
praecox are clearly to be regarded as having a disease to a
degree that disqualifies them for legal responsibility for their
actions. The date when the time was committed, the
defendant and appellant had an attack of insomnia which is
one of the symptoms of dementia praecox. The defendant
was arrested and taken to the police station and although
attempts were made by detectives to secure a statement
from him he was sent to the Psychopathic Hospital the day

following the commission of the crime. The crime dementia

praecox is usually preceded by much complaining and
planning. In these people, homicidal attacks are common,
because of delusions that their property is being
taken. Defendant is DEMENTED at the time he
perpetrated the serious offense. ACQUITTED.

People vs. Ambal

100 SCRA 325

People vs. Puno

Honorato Ambal and Felicula Ambal, 50 years married when by

quarrels and bickerings which were exacerbated by the fact that the
wife sometimes did not stay in the conjugal abode and chose to spend
the night in the poblacion of Mambajao. The couple had eight
children.The immediate provocation for the assault was a quarrel
induced by Felicula's failure to buy medicine for Ambal who was
afflicted with influenza. The two engaged in a heated alteration.
Felicula told her husband that it would be better if he were dead ("Mas
maayo ka pang mamatay").He went to the barangay captain and
informed that he killed his wife. After making that oral confession,
Ambal took a pedicab, went to the municipal hall and surrendered to a
policeman.During the trial, he pleaded not guilty and, thru his counsel
de oficio, the defense of Ambal was insanity. Dr. Balbas stated during
trial: Before the commission of the crime, he was normal. After the
commission of the crime, normal, but during the commission of the
crime, that is what we call Psychosis due to short frustration
tolerance.

Urge to kill the mambabarang because he will die if he doesnt kill the
mambabarang. He would like to go to jail rather die.
Able to social with other people.

WON Honorato Ambal can use the

defense of insanity as a exempting
circumstance.
1. Voluntary will
2. 2 TESTS
Right or wrong test
capacity to determine what
is right and wrong (Phil)
Irresistible impulse lost of
mental will to resist.

No, The law presumes that every person is of sound mind,

in the absence of proof to the contrary (US vs. Martinez, 34
Phil 305). The law always presumes all acts to be voluntary. It is
improper to presume that acts were executed unconsciously. In
order that insanity may be taken as an exempting circumstance,
there must be complete deprivation of intelligence in the
commission of the act or that the accused acted without the least
discernment. The alleged insanity of Ambal was not
substantiated by any sufficient evidence. The presumption of
sanity was not overthrown. He was not completely bereft of
reason or discernment and freedom of will when he
mortally wounded his wife. He was not suffering from any
mental disease or defect. The fact that immediately after
the incident he thought of surrendering to the lawenforcing authorities is incontestable proof that he knew
that what he had done was wrong and that he was going
to be punished for it. Mere abnormality of his mental
faculties does not exclude imputability. GUILTY OF

PARRICIDE.

People vs. Dungo

People vs. Yam-id

People vs.
Valledor

People vs. Belonio

People vs. Taneo

Potenciano Taneo and his wife lived in his parent's house in WON defendant acted while
Dolores, Ormoc. On January 16, 1932, a fiesta was being in a dream.
celebrated in the said barrio and guests were entertained in the
house, among them were Fred Tanner and Luis Malinao. Early that
afternoon, Potenciano went to sleep and while sleeping, he
suddenly got up, left the room bolo in hand and, upon
meeting his wife who tried to stop him, wounded her in the
abdomen. He also attacked Fred and Luis and tried to
attack his father, after which, he wounded himself.
Potenciano's wife, who was 7 months pregnant at that

Yes. The defendant acted while in a dream & his acts,

therefore, werent voluntary in the sense of entailing
criminal liability.
The apparent lack of motive for committing a criminal
act does not necessarily mean that there are none,
but that simply they are not known to us. Although an
extreme moral perversion may lead a man to commit
a crime without a real motive but just for the sake of
committing it. In the case at hand, the court found not

People vs. Doquena

time, died five days later as a result of the wound.

The defendant stated that when he fell asleep, he dreamed that
Collantes was trying to stab him with a bolo while Abadila held his
feet. That's why he got up and it seemed to him that his enemies
were inviting him to come down; he armed himself with a bolo and
left the room. At the door, he met his wife who seemed to say to
him that she was wounded. Then, he fancied seeing his wife really
wounded and in desperation wounded himself. As his enemies
seemed to multiply around him, he attacked everybody that came
his way.

only lack of motives for the defendant to voluntarily

commit the acts complained of (read: he loved his
wife dearly, he tried to attack his father in whose
house the lived and the guests whom he invited), but
also motives for not committing the acts.

Juan Ragojos and Epifanio Rarang were playing volleyball in the yard of their
school in Sual, Pangasinan. Valentin Doquena, the accused, intercepted the ball,
and threw it a Ragojos, who was hit in the stomach. Miffed, Ragojos chased
Doquena, and upon catching him, slapped Doquena on the nape, and punched
him in the face. After doing this, Ragojos went back to Rarang to resume playing
volleyball. Insulted, Doquena looked for something to throw at Ragojos,
finding none, he got his cousin's (Romualdo Cocal) knife, and
confronted Ragojos. Ragojo's denied Doquena's request for a fight and
resumed playing. Doquena stabbed the unaware Ragojos in the chest,
thereby killing the latter. The court held that in committing the act, the
accused acted with discernment and was conscious of the nature and
consequences of his acts, therefore his defense that he was a minor
was untenable (given that the Doquena was a 7th grade pupil, one of
the brightest in his class, and was an officer in the CAT program), and
thus convicted him of the crime of homicide. The court ordered him to be sent to
the Training School for Boys until he reaches the age of majority. Thus, the
appeal by the accused, stating that to determine whether or not there was
discernment on the part of the minor, the following must be taken into
consideration:

WON
Valentin
Doquena Yes, the accused acted with discernment. Accused
mistakes the discernment for premeditation, or at
acted with discernment.

a) The facts and circumstances which gave rise to the act committed.
b) The state of mind at the time the crime was committed
c) The time he had at his disposal
d) The degree of reasoning of the minor

least for lack of intention, as a mitigating

circumstance. However, the DISCERNMENT that
constitutes an exception to the exemption from
criminal liability of a minor under 15 years but over
nine, who commits an act prohibited by law, is his
MENTAL CAPACITY to understand the difference
between right and wrong, and such capacity may be
known and should be determined by taking into
consideration all the facts and circumstances afforded
by the records in each case, the very appearance, the
very attitude, the very comportment and behavior of
said minor, not only before and during the
commission of the act, but also after and even during
the trial.

Jose vs. People

Narvaez

Narvaez was awakened by a noise of Fleischer building a

fence.
Narvaez shot Fleischer because he was threatened.
Unlawful aggression against his property but it is incomplete
self-defense because there is no aggression against his life.

Worcester vs.
Ocampo

Worcester acting on defense in the crime

of libel.
Once a person is cast to him, attaches to
a person and will do necessary means
employed to prevent and repel it.

WON there is self-defense.

Attack on the person and

reputation.
Person may answer back as
self defense but should be a
fair answer and not libelous.

JUSTIFYING CIRCUMSTANCE
1. Since the act is accordance with law, therefore no criminal liability.
2. If there is no unlawful aggression, there is no self-defense.
3. Mere push is not self-defense.
4. If you accepted a challenge against a duel, once you agreed to a fight both of them are at fault. Both are
aggressors.
5. Unlawful aggression stops, when the attacker fleds.
6. Check the place, weapon used, consider the details. All the facts matter.
7. Sufficient provocation, must be enough to stir one into a defense.
8. BWS 2 INCIDENTS OR MORE.
IMPRINTED DANGER IN THE MIND OF THE WIFE.
9. No crime committed therefore civil liability is except is state of necessity of the person benefited.