Criminal Law I
Case Digests
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TABLE OF CONTENTS
URBANO v. IAC ……………………………………………….………. 3
G.R No. 729964 l January 7, 1988
PEOPLE v. CARANDANG …………………………….……………… 4
G.R. No. 175926 l July 6, 2011
PEOPLE v. OLARBE …………………………………………….……. 6
G.R. No. 227421 l July 23, 2018
PEOPLE v. MARZAN ………………………………………….………. 8
G.R. No. 207397 l September 24, 2018
URBANO v. PEOPLE ………………………………………….…...….. 9
G.R. No. 182750 l January 20, 2009
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URBANO v. IAC
G.R No. 729964 l January 7, 1988
Facts:
In 1980, Filomeno Urbano went to his rice field at Pangasinan and
found his palay storage flooded with water coming from an overflowed
irrigation canal. He learned that it was Marcelo Javier responsible for
such instance and angrily demanded he pay for the damaged palay.
Heated argument transpired between the two. Urbano unsheathed his
bolo and hacked Javier injuring the right palm of his hand as well as
his left leg. Javier was brought to the nearest physician for treatment.
Soon after, through mediation by councilman Solis, Urbano and Javier
reached an amicable settlement – Urbano would pay Javier P700.00
for medical expenses incurred. Urbano has fully complied with the
obligation. However, weeks later, Javier was rushed to the hospital due
to lock jaw and convulsions caused by tetanus; his wounded right palm
was infected. Javier died in the hospital.
Due to this, Urbano was charged with the crime of homicide. He claims
that the proximate cause of Javier’s death was due to his own
negligence, as Javier went fishing without allowing his wound to heal
properly. Circuit Criminal Court of Dagupan City found Urbano guilty.
Aggrieved, Urbano appealed said decision. Hence this petition.
Issue: W/N the wound caused by Urbano was the proximate cause of
Javier’s death.
Held:
NO. The Supreme Court speaking through Justice Gutierrez Jr., ruled
that an accused is criminally responsible for all the natural and logical
consequences resulting from any acts in violation of law; thus, in case
of death of victim, said acts must be the direct, natural, and logical
consequence of the wounds inflicted, and the proof must convince a
rational mind beyond reasonable doubt. In this case, the wound
inflicted by Urbano on Javier’s right palm was indeed the remote
cause, but the proximate cause of Javier’s death is the infection
caused due to failure to observe necessary precautions when he
returned to fishing. The infection is distinct and foreign to the crime
committed by Urbano. Thus, Urbano is acquitted from the criminal
liability.
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PEOPLE v. CARANDANG
G.R. No. 175926 l July 6, 2011
Facts:
Drug enforcement unit of La Loma Police Station received a call from
the sister of Milan regarding a supposed drug deal that will transpire in
her house located in Quezon city. When the police team reached the
place, they surrounded the said house. The team saw the door to
Milan’s room was open; Carandang, Milan, and Chua is inside. SPO2
Red told the group that the persons inside the room would not engage
in violence. However, when they introduced themselves as police
officers, Milan immediately shut the door. When PO2 Alonzo and
SPO2 Red pushed the door open, gunshots were suddenly fired killing
them both on the spot. SPO1 Montecalvo, who was behind SPO2 Red
the whole time was also shot but did not get killed. SPO1 Estores heard
Chua order Milan to lunge towards SPO1 Montecalvo to which the
former did. But SPO1 Montecalvo was able to fire his gun and hit Milan.
SPO1 Estores went inside the house and pulled SPO1 Montecalvo out.
Reinforcements came and SPO1 Montecalvo and Milan were brought
to Chinese General Hospital. Carandang and Chua remained inside
the house for several hours and refused to surrender. They requested
the presence of a certain Colonel Reyes and Ramon Tulfo. It was only
around midnight that Carandang and Chua surrendered. The bodies of
SPO2 Red and PO2 Alonzo were found inside the house; slumped on
the floor with broken legs and gunshot and grenade shrapnel wounds.
The post-mortem examination of SPO2 Red and PO2 Alonzo’s body
reveal that they died of gunshot wounds. On the other hand, SPO1
Montecalvo was hit by the bullet in the nape, it was removed by an
operation.
The RTC found Carandang, Milan, and Chua guilty beyond reasonable
doubt for the murder of SPO2 Wilfredo Pilar Red and PO2 Dionisio
Alonzo, qualified by treachery and acting in conspiracy with each other.
They are also guilty beyond reasonable doubt of frustrated murder.
Aggrieved, they appealed the decision to CA. CA affirmed with
modification on penalty the decision of RTC. Only Milan and Chua
appealed to the Supreme Court as Carandang is no longer interested.
Milan and Chua contend that they are only liable of homicide and
frustrated homicide, as the qualifying circumstance of treachery was
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not proved. They also claim lack of evidence that they conspired with
Carandang.
Issue: W/N conspiracy exists between all the accused.
Held:
YES. The Supreme Court speaking through Justice Leonardo-De
Castro, conspiracy exists when two or more persons come to an
agreement concerning the commission of a felony and decide to
commit it. It is not necessary to show actual agreement manifesting
plan or motive to commit the crime as proof lies on the concerted action
before, during, and after the crime – this is what demonstrates the unity
of design and objective. Once conspiracy is established, the act of one
is the act of all. In this case, there is conspiracy because before
Carandang shot the victims, Milan closed the door; this allowed
Carandang to wait in ambush. Chua also directed to attack
Montecalvo. The facts clearly show evidence of the unity of purpose in
the minds of the three. Thus, there is existence of conspiracy in all the
accused.
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PEOPLE v. OLARBE
G.R. No. 227421 l July 23, 2018
Facts:
In Laguna, Rodolfo Olarbe shot and hack Romeo Arca on different
body parts using caliber. 22 and a bolo which resulted to the latter’s
death. Olarbe voluntarily surrendered to the police after the incident.
For his defense, Olarbe invoked self-defense. He claims that when he
and his wife were sleeping in their house, they were suddenly
awakened by a gunshot and shouting from a drunk Arca who
threatened to kill them. Arca forcibly entered their house and wreaked
havoc. Olarbe grabbed the gun from him and managed to shoot Arca
which caused the latter to lean sideward. Regardless being shot, Arca
took out the bolo from his waist and continued to attacked them. Olarbe
grabbed the weapon and wrestled with Arca until he was able to hack
the him.
Olarbe was charged before RTC of Laguna with the crime of murder
for killing Romeo Arca. He pleaded self-defense and defense of
stranger. RTC convicted him guilty of murder as justifying
circumstance was not proved. There was unlawful aggression on his
part and he also employed treachery when he killed Arca. But since
Olarbe surrendered, he is entitled to mitigating circumstance. On
appeal, the CA affirmed with modification the penalty.
Issue: W/N Olarbe’s acts constitutes self-defense and defense of
stranger.
Held:
YES. The Supreme Court speaking through Justice Bersamin ruled
that under Art. 11 of RPC, an indispensable requisite for justifying
circumstances is that there must be an unlawful aggression from the
accused or stranger. Without unlawful aggression, a person is not
entitled to justifying circumstance. The test for the presence of unlawful
aggression is whether aggression from a person put real peril in the life
or personal safety of the person defending himself; said peril must not
be an imagined or imaginary threat. In this case, Arca armed with a
gun and bolo, committed unlawful aggression when he forcibly entered
the house and assaulted Olarbe as well as his common-law spouse
with the weapons he brought. Such armed assault is not a mere
threatening act, Olarbe felt that his and his spouse lives were in in
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extreme peril which prompted Olarbe to repel the unlawful aggression
from Arca. For had it been that he did not defend himself, it would have
cost him his life. Thus, Olarbe’s acts constitute self-defense.
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PEOPLE v. MARZAN
G.R. No. 207397 l September 24, 2018
Facts:
Several witnesses saw Carpio Marzan entered the house of his
brother, Apolonio Marzan. Not long after, Apolonio was heard
screaming. Carpio went out of Apolonio’s house wearing a bloodstained shirt and holding a bladed instrument dripping with blood.
Bernardo Marzan, also another brother, tried to pacify Carpio but the
latter stabbed Bernardo in the stomach. Apolonio died and the cause
of death was massive internal bleeding due to multiple penetrating stab
wounds. For his defense, Carpio claims insanity. Isabel Marzan,
Carpio’s wife, claims that he has been suffering from a mental
condition. During the day of the incident, Carpio was going back and
forth muttering something. Isabel and others tried to calm him but he
suddenly ran towards Apolonio’s house while holding a bolo. After the
incident, he just sat down and remained “tulala” until the police arrived.
He was diagnosed by Dr. Roxas of NCMH as suffering from
schizophrenia.
Carpio was charged with the crime of murder and frustrated murder
before the RTC of Camiling, Tarlac. The RTC found him guilty beyond
reasonable doubt of murder and lesser offense of frustrated murder.
On appeal, CA affirmed the decision of RTC with modification on the
penalty.
Issue: W/N Carpio’s plea of insanity is tenable.
Held:
NO. The Supreme Court speaking through Justice Del Castillo ruled
that in order to be entitled to exempting circumstance under Art 12 of
the RPC, the defense must prove that the accused was deprived of
complete intelligence in the commission of the crime. Also,
schizophrenia does not fall as an exempting circumstance. In this case,
Carpio was not completely deprived of intelligence prior to and during
the commission of the crime as he was sane enough to help his mother
get up, as well as to surrender himself and the bolo he used to the
police. He also has in possession a driver’s license that he regularly
used as tricycle driver. Thus, the plea of insanity is not tenable.
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URBANO v. PEOPLE
G.R. No. 182750 l January 20, 2009
Facts:
In the evening of September 1993, while inside the compound of
Lingayen Water District (LIWAD) in Pangasinan, Brigido Tomelden and
Rodel Urbano both drunk, had heated altercation with one another.
Tomelden hurled insulting remarks to Urbano. The exchange of words
soon led to exchange of blows. For a brief moment, their co-workers
were able to break up the fight, however Tomelden and Urbano
refused to calm down and continued throwing fist blows at each other.
Urbano delivered a “lucky punch” on Tomelden’s face which caused
the latter’s nose bleed. Soon after, Tomelden was unconscious.
Urbano and his co-workers brought Tomelden to an office in LIWAD
where he spent the night. When he went home the next day, he told
his wife, Rosario about the fight. He complained of pain in his nape,
head and ear. Rosario immediately brought him to Lingayen
Community Hospital. Days later, Tomelden again complained of
dizziness, headache, and other pains. The doctors observed that he
was frequently vomiting and in a state of drowsiness. Rosario brought
him to Sison Memorial Provincial Hospital in Dagupan City where he
was diagnosed with brain injury caused by the fighting incident.
Tomelden was confined for days but due to financial constraints, he
was discharged despite no signs of improvement. Upon reaching their
house, Tomelden complained of extreme head pain; Rosario rushed
him to the hospital but he was not responding to any stimulant
anymore. Tomeden died that day. Dr. Arellano of Lingayen Community
Hospital stated that the cause of death was cardio-respiratory arrest
secondary to cerebral concussion with resultant cerebral hemorrhage
due to fighting incident.
For his defense, Urbano denied the intention to kill, and claimed that it
was hypertension that caused Tomelden’s death.
Urbano was charged for homicide before the RTC of Lingayen,
Pangasinan, and the trial court found him guilty beyond reasonable
doubt. On appeal, the CA affirmed the decision of RTC on the ground
that the lucky punch was the proximate cause of Tomelden’s death but
with modification on the award of moral damages.
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Issue: W/N lack of intention to commit so grave a wrong and sufficient
provocation on the part of the victim is a mitigating circumstance.
Held:
YES. The Supreme Court speaking through Justice Velasco ruled that
provocation either as a mitigating circumstance or as an essential
element of self-defense, refers to unjust or improper conduct of the
offended party capable of exciting, inciting, or irritating anyone. It is not
enough that the provocative act be unreasonable or annoying; such
provocation must be sufficient to excite a person to commit a wrongful
act. In this case, it was Tomelden who first made the insulting remarks,
and challenged Urbano to a fist fight – this constituted sufficient
provocation. Testimony of witnesses also proved that Urbano being
much smaller than Tomelden, tried to avoid the fight and parry only the
blows but the lucky punch still ended the fight. Thus, there is clear
mitigating circumstance.
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