University

of the Philippines College of Law

JTR, 1-D


Topic Mitigating Circumstances
Case No. No. L-30801. March 27, 1974
Case Name People v. Ural
Ponente Aquino, J.

DOCTRINE
Art. 13, Paragraph 3: The following are mitigating circumstances: (3) that the offender had no intention
to commit so grave a wrong as that committed

SUMMARY
Policeman Ural boxed a prisoner to death but didnt mean it

RELEVANT FACTS

Facts based on testimony of Brigido Alberio, former detention prisoner
o He saw Policeman Ural inside the jail, boxing the detention prisoner, Felix Napola. Eventually,
Napola collapsed on the floor and Ural even stepped on his prostate body
o Ural went out of the cell and after a while returned with a bottle, then poured its contents over
the boys and ignited it with a match and left the cell
o Ural saw Alberio and warned him: You better keep quiet of what I have done.
The municipal health officers certified that were it not for medical intervention, the burns would caused
death (2nd degree burns which could have resulted to toxemia and tetanus infection) Napola died on
August 25, 1966 due to burns
According to Ural, he heard a scream for help from Napola and found the latters shirt in flames, which
Ural removed with some assistance. Ural didnt summon a doctor because, according to Napola, the
burns were not serious. BUT court believed Alberios testimony over Urals
Fact 3.

ISSUE

W/N Ural is liable for his actions

RATIO DECIDENDI

Issue Ratio
W/N Ural is liable for his YES
actions
1. Under article 4 of the RPC: Criminal liability shall be incurred by any
person committing a felony (delito) although the wrongful act done be
different from that which he intended
a. He who is the cause of the cause if the cause of the evil caused
2. US v Escalona: an individual who unlawfully inflicts wounds upon
another person, which result in the death of the latter, is guilty of the
crime of homicide, and the fact that the injured person did not receive
proper medical attendance does not affect the criminal responsibility

 University of the Philippines College of Law
JTR, 1-D

3. Aggravating circumstance was appreciated Art. 14, par. 1: the accused
took advantage of his public position
4. The trial court failed to appreciate the mitigating circumstance that the
offender had no intention to commit so grave a wrong as that
committed (Par. 3, Art. 13, RPC)
a. Manifest from the proven facts that Ural had no intent to kill him.
He only wanted to maltreat Napola may be because in his
drunken condition, he was making a nuisance of himself inside
the detention cell. When Ural realized the fearful consequences
of his felonious act, he allowed Napola to secure medical
treatment at the municipal dispensary.
b. Lack of intent to commit so grave a wrong offsets the generic
aggravating circumstance of abuse of his official position.

RULING

Affirmed trial courts judgement. Reclusion perpetua, which is the medium period of the penalty for murder.