PEOPLE V.

UMAWID, 09 June 2014

DOCTRINE: Aberratio ictus is mistake in the blow. It is a manner or incurring criminal liability
according to Paragraph 1, Article 4, Revised Penal Code. A circumstance that neither exempted
an offender from criminal responsibility nor mitigated his criminal liability.

FACTS:
Vicente Ringor was staying with his 2-year old granddaughter, Maureen Joy Ringor at the
terrace of their house. Suddenly, Umawid appeared and started attacking Vicente with a panabas
while the latter was able to evade Umawid’s blows, nevertheless hit Maureen on her abdomen and
back, causing her instantaneous death. Thereafter, Umawid went to a nearby house where his
nephew, Jeffrey was awaken and saw his uncle charging at him with his panabas. Jeffrey rushed
inside the house but Umawid was able to prevent Jeffrey from closing the door of the house. Jeffrey
crouched and covered his head with his arms to shield him from Umawid’s impending attacks.
Umawid delivered fatal hacking blows to Jeffrey, causing the mutilation of the latter’s fingers.
Umawid set up the defense of insanity by presenting the testimonies of Dr. Quincina and
Dr. Juliana to bolster his claim. Dr. Quincina testified that he evaluated Umawid’s psychiatric
condition and found that the latter was manifesting psychotic symptoms. However, he could not
tell with certainty whether Umawid was psychotic at the time of the commission of the crimes.
While Dr. Juliana failed to testify on Umawid’s mental state since she merely referred the latter to
another doctor for further evaluation. It held that by invoking the defense of insanity, Umawid had,
in effect, admitted the commission of the crimes but nevertheless pleaded to be exonerated from
criminal liability. However, he failed to prove by clear and positive evidence that he was actually
insane immediately preceding the time of the commission of the crimes or during their execution.

ISSUE:
Whether there is mistake in the blow in Maureen’s death

RULING:
Yes. The Court observes that Maureen’s death is a case of aberratio ictus or mistake in
blow, given that the fatal blow therefore was only delivered by mistake as it was actually Vicente
who was Umawid’s intended target. Under Article 4 (1) of RPC, criminal liability shall be incurred
by any person committing a felony although the wrongful act done be different from that which
he intended. In this regard, Umawid’s single deed actually resulted in the: (a) Attempted Murder
of Vicente; and (b) Consummated Murder of Maureen. This may be classified as species of
complex crime defined under Article 4829 of the RPC. However, considering that the information
charged him with the Murder of Maureen, Umawid cannot be convicted of a complex crime
because to do so would be violative of his right to due process. An accused cannot be convicted of
an offense unless it is clearly charged in the complaint or information. The Court hereby finds
Umawid guilty beyond reasonable doubt of the crimes of Murder and Frustrated Murder defined
and penalized under Article 248 of the RPC.
 ROMUALDEZ V. COMELEC, 11 December 200
DOCTRINE: The “void-for-vagueness” of facial challenge test means that law is facially invalid
if it lacks comprehensible standards that the men of common intelligence must necessarily guess
at its meaning and differ as to its application.

FACTS:
Petitioner Carlos Romualdez, was running as a candidate for Congress in the 2nd District
of Leyte in the 2001 elections. Prior to the petitioner’s filing of candidacy, private respondent
Dennis Garay filed a complaint before COMELEC Burauen, Leyte, charging petitioners with
violation of Sec 261 (y)(2) and (y)(5) of the Omnibus Election Code and Sec 12 of the Voter’s
Registration Act (RA 8189).
Garay contended that the petitioner and his wife, Erlinda Romualdez made false and
untruthful representations in violation of Section 12 of RA 8189 by indicating therein that they are
residents of San Jose Street, Burauen, Leyte, when in in fact, they are still residents and registered
voters of Quezon City; and that knowing fully well said truth, intentionally and willfully, did not
fill the blank spaces in said applications corresponding to the length of time which they have
resided in Burauen, Leyte. On the other hand, the petitioners contended that they intended to reside
in Buarauen, Leyte and took actual residence in Burauen, Leyte for 5 years.
COMELEC charged the petitioners with violations of Section 10(g) and (j), in relation to
Section 45(j) of the RA 8189. The petitioners contended that Section 45 (j) of the RA 8189 was
void for being vague as it did not refer to a definite provisions of the law, the violation of which
would constitute an election offense.

ISSUE:
Whether criminal statute may be facially challenged considering the void-for-vagueness
doctrine.

RULING:
The facial invalidation or an "on-its-face" invalidation of criminal statutes is not
appropriate. The void-for-vagueness doctrine holds that a law is facially invalid if men of common
intelligence must necessarily guess at its meaning and differ as to its application. However, this
Court has imposed certain limitations by which a criminal statute, as in the challenged law at bar,
may be scrutinized. In our jurisdiction, only statutes on free speech, religious freedom and other
fundamental rights may be facially challenged. Under no case may ordinary penal statutes be
subjected to a facial challenge. Indeed, an "on-its-face" invalidation of criminal statutes would
result in a mass acquittal of parties whose cases may not have even reached the courts. Such
invalidation would constitute a departure from the usual requirement of "actual case and
controversy" and permit decisions to be made in a sterile abstract context having no factual
concreteness. Therefore, void for vagueness does not apply to Section 45 (j) and it is not vague
and they are not denied of due process.
 PEOPLE V. ESPERANZA, 19 June 2017
DOCTRINE: Conspiracy is not a harmless innuendo to be taken lightly or accepted at every tum.
It is a legal concept that imputes culpability under specific circumstances. As such, it must be
established as clearly as any element of the crime. The quantum of evidence to be satisfied is, we
repeat, beyond reasonable doubt.

FACTS:
An Information was filed charging accused-appellant Roberto Esperanza Jesalva alias
"Robert Santos", Ryan Menieva and Junie Ilaw alleging that accused, conspiring together,
feloniously with intent to kill with evident premeditation, treachery and taking advantage of
superior strength, attack, assault and employ personal violence upon the person of Amel Ortigosa,
by then and there stabbing him with a sharp bladed instrument hitting him on the chest, causing
his untimely death.
Accused-appellant denied any participation in Ortigosa's stabbing. He claimed that on the
night of the incident, he was waiting for his sister on the corner of Dupax Street. While waiting,
he saw and heard people running and shouting which caused him to leave the place. RTC and CA
held that appellant is liable for murder as he conspired with the other accused.

ISSUE:
Whether there is conspiracy between the a

RULING:
No. To determine if accused-appellant conspired with Menieva and Ilaw, the focus of the
inquiry should necessarily be the overt acts of accused-appellant before, during and after the
stabbing incident. In this case, no evidence showing that appellant was purposely waiting for
Ortigosa at the time and place of the incident and that Menieva and Ilaw were on standby, awaiting
for accused-appellant's signal. In this case, all that accused-appellant did was to stare and point at
the victim and his companions. These, however, are not crimes Mere knowledge, acquiescence or
approval of the act, without the cooperation and the agreement to cooperate, is not enough to
establish conspiracy.
Even if the accused were present and agreed to cooperate with the main perpetrators of the
crime, their mere presence does not make them parties to it, absent any active participation in the
furtherance of the common design or purpose. In this case, while accused-appellant's presence and
act of pointing at the victim and his group may mean he approved of the crime or that he was ready
to assist his co-accused, absent any other overt act on his part, there is no conspiracy. Prosecution
must establish conspiracy beyond reasonable doubt. A conviction premised on a finding of
conspiracy must be founded on facts, not on mere inferences and presumption. The accused-
appellant ROBERTO ESPERANZA JESAL VA alias "Robert Santos" is acquitted on reasonable
doubt of the crime charged.
 PEOPLE VS CABALQUINTO, 19 September 2006
DOCTRINE: Sec. 44 of RA 9262 similarly provides that confidentiality.—All records pertaining
to cases of violence against women and their children including those in the barangay shall be
confidential and all public officers and employees and public or private clinics or hospitals shall
respect the right to privacy of the victim. Whoever publishes or causes to be published, in any
format, the name, address, telephone number, school, business address, employer, or other
identifying information of a victim or an immediate family member, without the latter’s consent,
shall be liable to the contempt power of the court.

FACTS:
ABC testified that she is the common-law wife of Cabalquinto and that they have four
children namely BBB, CCC, the child-victim AAA, and DDD. At around 8:45PM of November
13, 1998, she was on her way home. Since there is a half-inch gap between the door and the wall,
she peeped through the gap and saw Cabalquinto lying face down making pumping motions on
their daughter, AAA, who was lying underneath him with her panties pulled down. When she
heard Cabalquinto tell AAA to open her legs ("ibuka mo"), she kicked and pounded the door.
Cabalquinto immediately lay down. AAA then stood up and opened the door. ABC entered the
room and confronted Cabalquinto who only denied her accusation. ABC and her daughter AAA
testified during the police investigation, AAA revealed to the police that a similar incident
happened to her on November 8, 1998, the day of her friend’s birthday celebration. Trial court
found the accused guilty of the crime of rape.
The mother of the child abuse victim submitted that confidentiality and the best interest of
the child must prevail over public access to information and pleaded that her daughter’s case, as
well as those of a similar nature, be excluded from the Web Page.

ISSUE:
Whether the identity of the aggrieved party should not be disclosed in line with the right to
privacy and confidentiality

RULING:
Yes. Posting of the full text of decisions in cases involving child abuse on the Supreme
Court Web Page violates the right to privacy of the aggrieved parties. Records of the cases shall
be treated with utmost confidentiality. In order to determine whether the subject matter upon which
the right to privacy being invoked falls within the constitutionally-protected zone of privacy, it
must be shown that the person’s expectation of privacy is reasonable. The Court shall withhold
the real name of the victim-survivor and shall use fictitious initials instead to represent her.
Likewise, the personal circumstances of the victims-survivors or any other information tending to
establish or compromise their identities, as well those of their immediate family or household
members, shall not be disclosed.
 PEOPLE V. ASENIERO, 10 April 2019
DOCTRINE: Voluntary surrender mitigates the penal liability of the accused the following
requisites must be established: first, the accused has not been actually arrested; second, the
accused surrenders himself to a person in authority or the latter’s agent; and third the surrender
is voluntary. The said requisites were sufficiently proven by the defense.

FACTS:
On 24 August 2003, in the Municipality of Bato, Leyte, the accused, Romeo Aseniero with
deliberate intent to kill employing treachery and evident premeditation, did then and there willfully
and feloniously attack, hack and stab Dominador Ranes with a long bolo which the accused had
provided himself for the purpose, thereby causing and inflicting upon the victim multiple stabbed
and hacked wounds on the different parts of his body causing the immediate death of Dominador
Ranes. In the incident, Analyn Gomez was present, she is the former girlfriend of the accused and
the current girlfriend of Dominador Ranes. She revealed that just one month after her break-up
with the accused, she started a relationship with the victim. After the incident, the accused
voluntarily surrendered to the police authorities.

ISSUE:
Whether the voluntary surrender should consider in imposing penalty

RULING:
For voluntary surrender to mitigate the penal liability of the accused the following
requisites must be established: first, the accused has not been actually arrested; second, the accused
surrenders himself to a person in authority or the latter’s agent; and third the surrender is voluntary.
The said requisites were sufficiently proven by the defense.
SPO3 Wilfredo Vargas testified that the accused voluntarily surrendered at the Matalom
Police Station on August 24, 2003. This was corroborated by Analyn who admitted that indeed
Romeo immediately surrendered to the authorities after the incident. Roel likewise testified that
he accompanied the accused to the police station. Thus, the mitigating circumstance of voluntary
surrender should be considered in the imposition of the penalty. Given that Romeo voluntarily
surrendered, Article 64(2) states that when only a mitigating circumstance attended the
commission of the felony, the penalty shall be imposed in its minimum period.
 PEOPLE VS BARTOLOME, 06 February 2013

DOCTRINE: Instigation is the means by which the accused is lured into the commission of the
offense charged in order to prosecute him. On the other hand, entrapment is the employment of
such ways and means for the purpose of trapping or capturing a lawbreaker.

FACTS:
A police inspector conducted a buy-bust operation against the accused, Noel Bartolome.
Paras was the poseur-buyer and given a P100.00 bill as the marked money. It was agreed that the
informant would drop a cigarette butt in front of the suspect to identify him to Paras; and that Paras
would scratch his head to signal to the buy-bust team that the transaction with the suspect had been
consummated. During the buy-bust, the informant then approached a person who was standing in
front of the store and dropped a cigarette butt in front of the person. Paras went towards and tried
to buy to the suspect after which he handed the marked P100.00 bill to the suspect, who in turn
drew out a plastic sachet containing white substances from his pocket and gave the sachet to Paras.
With that, Paras signaled the team members, Paras grabbed the suspect. PO3 Antonio, another
member of the team, confiscated the marked P100.00 bill from the suspect, who was identified as
Noel Bartolome y Bajo. Paras immediately marked and requested in writing the PNP Crime
Laboratory to conduct a laboratory examination of the contents of the plastic sachet. Thereafter
PNP Crime Laboratory confirmed that that the substance is shabu, a dangerous drug.

ISSUE:
Whether the transaction resulting to the arrest of Bartolome is an instigation.

RULING:
No. Instigation is the means by which the accused is lured into the commission of the
offense charged in order to prosecute him. On the other hand, entrapment is the employment of
such ways and means for the purpose of trapping or capturing a lawbreaker. Thus, in instigation,
officers of the law or their agents incite, induce, instigate or lure an accused into committing an
offense which he or she would otherwise not commit and has no intention of committing. But in
entrapment, the criminal intent or design to commit the offense charged originates in the mind of
the accused, and law enforcement officials merely facilitate the apprehension of the criminal by
employing ruses and schemes; thus, the accused cannot justify his or her conduct. In instigation,
where law enforcers act as co-principals, the accused will have to be acquitted. But entrapment
cannot bar prosecution and conviction. As has been said, instigation is a “trap for the unwary
innocent,” while entrapment is a “trap for the unwary criminal. As a general rule, a buy-bust
operation, considered as a form of entrapment, is a valid means of arresting violators of Republic
Act No. 9165. It is an effective way of apprehending law offenders in the act of committing a
crime. In a buy-bust operation, the idea to commit a crime originates from the offender, without
anybody inducing or prodding him to commit the offense.
 PEOPLE VS DIMAALA, 17 July 2017
Doctrine: Death of the accused pending appeal of his conviction extinguishes his criminal liability
as well as the civil liability based solely thereon.

FACTS:
Agapito Dimaala y Arela is guilty beyond reasonable doubt of the crime charged for the
treacherous killing of Rodrigo Marasigan. Said accused is hereby sentenced to Reclusion Perpetua
without eligibility for parole. Accused-appellant appealed his conviction before the Court of
Appeals (CA). He filed a Notice of Appeal from the CA's Decision, but later on decided not to
pursue his appeal. Thus, he filed a Motion to Withdraw Appeal with Prayer for Immediate Issuance
of Entry of Judgment, which the Court granted in its Resolution. Following the closure and
termination of the case, the Court declared the finality of the aforesaid Resolution and issued an
Entry of Judgment. Meanwhile, the Court received a letter from the Bureau of Corrections
informing it that accused-appellant had died on August 23, 2016 at the New Bilibid Prison
Hospital, as evidenced by the Certificate of Death attached thereto.

ISSUE:
Whether criminal liability ipso facto extinguished upon the death of the accused

RULING:
It is settled that the death of accused-appellant prior to his final conviction by the Court
renders dismissible the criminal case against him. Article 89 (1) of the Revised Penal Code
provides that the criminal liability is totally extinguished by the death of the accused, to wit: Article
89. How criminal liability is totally extinguished – Criminal liability is totally extinguished: 1. By
the death of the convict, as to the personal penalties; and as to pecuniary penalties, liability therefor
is extinguished only when the death of the offender occurs before final judgment.
The Court explained the effects of the death of an accused pending appeal on his liabilities:
1. Death of the accused pending appeal of his conviction extinguishes his criminal liability as well
as the civil liability based solely thereon. As opined by Justice Regalado, in this regard, "the death
of the accused prior to final judgment terminates his criminal liability and only the civil liability
directly arising from and based solely on the offense committed, i.e., civil liability ex delicto in
senso strictiore."
In this relation, the Court stresses that accused-appellant's civil liability based on sources
other than the subject delict survives, and the victim may file a separate civil action against the
estate of accused-appellant, as may be warranted by law and procedural rules.