Criminal Cases

Alano, Justine Bea D.

U.S. vs. Fowler
G.R. No. L-496
Dec. 31, 1902
Facts:
• The defendants have been accused of theft of 16 bottles Of
champagne on Aug. 12, 1901, while on board the transit Lawton
which was then navigating the high seas.
• Said bottles of champagne form part of the cargo of the said vessel
and were owned by Julian Lindsay.
• The bottles of champagne were taken with intent to gain, and with
intent to appropriate the same, without violence or intimidation, and
without the consent of the owner.
Issue:
• WON the court has jurisdiction to try the accused for the theft alleged
to have been committed on the high seas.
Held:
NO. The court has no jurisdiction to try the case for it was shown in the
information that the crime was commited in high seas and not in the city of
Manila, or within the territory comprising the bay of Manila, upon the seas
within the 3-mile limit to which the jurisdiction of the court extends. Act. No.
76, does not also expressly confer jurisdiction or authority upon this court to
take cognizance of all crimes committee on board vessels on the high seas.
While the provision of the law are clear and precise with civil admiralty or
maritime cases, such are not true with criminal cases. Art. 56(8) defines the
jurisdiction of the court of First Instance in criminal cases for crimes
committed on board vessels registered or licensed in the Ph islands. The
transport not being a vessel of this class, our courts are without jurisdiction to
take cognizance of a crime committed on board the same. WHEREFORE, the
order appealed should be affirmed sustaining the demurer, and ordering the
discharge of the Defendants, with the costs to the Government.
People of the Philippines vs.
Gumimba
G.R. No. 174056
Feb. 27, 2007
Facts:
• On April 17, 1997, appellant Gumimba and co-accused Abapo were
charged before the RTC, with the crime of rape with homicide of an 8
yr. Old child.
• It was on April 8, 1997 that the two conspired with each other and
succeeded in having carnal knowledge with the minor and as a result
she suffered 6-12 o’clock lacerated wounds of the vagina as well as
fatal stab wounds on the different parts of her body which were the
direct cause of her death.
• During the arraignment, appelant and Abapo both entered a plea of
not guilty.
• However, all of the testimonies of the witnesses pointed that the
appellant alone committed the crime through the same confessions
the appellant told them.
• Appellant then manifested through counsel that he would like to
change his plea into a plea of guilty.
• On March 10, 1999, the RTC promulgated its decision and found the
appellant guilty beyond reasonable doubt and acquitted Abapo for his
guilt was not established beyound reasonable doubt.
Issue:
• WON the appellant’s guilt was established by evidence beyond
reasonable doubt.
Held:
YES. There was enough evidence on record to sustain the judgement of
conviction of the accused independent from his plea of guilty. Appellant’s
plea of guilt was made improvidently and it is rendered inefficacious. Apart
frim his testimony upon changing his plea to a plea of guilt, he also gave a
subsequent testimony when he was presented by the prosecution as a
witness against his co-accused. Such testimony constitutes a judicial
confession and replete with details the deficiencies made on his early plea of
guilt improvident. The second testimony were clear to show the
voluntariness and comprehension on the appellant’s plea as to how he raped
and killed the victim. WHEREFORE, the decision of the CA is AFFIRMED with
modifucation sentencing the appellant to suffer the penalty of reclusion
perpetua without eligibility for parole and to pay the heirs of the vuctim a
certain amount of money.
People of the Philippines vs.
Maningding
G.R. No. 195665
Sept. 14, 2011
Facts:
• On Sept. 13, 2006 at around 10:25pm, Marlon, the victim, and his
brother were conversing with each other while seated on a bench
near a sari-sari store. While such was transpiring, the accused arrived.
They both greeted the accused, but the latter did not respond. The
accused, which apparantly armed with a knife, suddenly held the
victim’s right hand, raised it and thrust the knife with his left hand.
The accused then pulled the knife and ran away. The victim incurred a
fatal wound which eventually led to his death.
Issue:
• WON the act of the accused-appellant were justified through self-
defense.
Held:
NO. The SC sustained the conviction of accused-appellant. The Court
held that self-defense does not exist in the present case. It is a rule that
when an accused claims the justifying circumstance of self-defense, the
burden of evidence, therefore, shifts to the accused’s side to prove that
the elements of self-defense exist, thus, justifying his acts. In this case,
the accused failed to establish such elements to constitute self-
defense. WHEREFORE, the appeal was DENIED and the accused was
rendered guilty beyond reasonable doubt of the crime murder, and is
sentenced to suffer the penalty of reclusion perpetua and ordered to
indemnify the heirs of the victim.
Enrile vs. Salazar
G.R. No. 92163
June 5, 1990
Facts:
• On Feb. 27, 1990, Sen. Enrile was arrested by the NBI with a warrant
issued by the RTC judge of Quezon City charging Sen. Enrile, the
spouses Rebecco and Erlinda Panlilio, and Honasan with the crime of
rebellion with murder and multiple frustrated murder allegedly
committed during the period of the failed coup attempt from Nov. 29
to Dec. 10, 1990.
• On the next day, Sen. Enrile filed a petion for habeas corpus alleging
that he was deprived of his constitutional rights for having been:
1. Held to answer for criminal offense which does not exust in the
statute books;
2. Denied of due process;
3. Denied of his right to bail; and
4. Arrested and detained on the strength of a warrant issued without
the judge who issued it first having personally determined the
existence of probable cause.
• On the consolidated return filed by the OSG for the respondents, it
stated that the petioner’s case does not fall within the Hernandez
ruling because the information Hernandez charged murders and
other common crimes committed as a necessary means for the
commision of rebellion, whereas the information against Sen. Enrile
et al. charged murder and frustrated murder committed on the
occasion, but not in furtherance, of rebellion.
Issue:
• WON the petitioner has committed complex crimes (delito compleio)
arising from an offense being a necessary means for committing
another, which is referred to in the second clause of Art. 48 of the
Revised Penal Code.
Held:
NO. The petitioner did not committed complex crimes, hence Art. 48 of
the RPC is not applicable in the given case. If two crimes were not
complexed and are punished separately, in the absence of aggravating
circumstances, the extreme penalty could not be imposed upon him.
However, under Art. 48, said penalty would have to be meted out to
him, even in the absence of a single aggravating circumstance. Thus,
said provision would be unfavorable to the movant if applied.
Petitioner’s contentions were ruled by the Court wherein the petitioner
was charged with the crime of simple rebellion which is punishable by
the RPC.
The Court reiterates that based on the doctrine enunciated in People
vs. Hernandez, the questioned information filed against petitioners
Juan Ponce Enrile and the spouses Rebecco and Erlinda Panlilio must be
read as charging simple rebellion only, hence said petitioners are
entitled to bail, before final conviction, as a matter of right. The Court's
earlier grant of bail to petitioners being merely provisional in character,
the proceedings in both cases are ordered remanded to the respondent
Judge to fix the amount of bail to be posted by the petitioners. Once
bail is fixed by said respondent for any of the petitioners, the
corresponding bail bond flied with this Court shall become functus
oficio. No Pronouncement as to costs.