IVLER VS SAN PEDRO (RECKLESS IMPRUDENCE IS A SINGLE CRIME; HELD: The Supreme Court reversed the ruling of the

urt reversed the ruling of the RTC. Petitioner’s conviction in

the case of reckless imprudence resulting in slight physical injuries bars his
ITS CONSEQUENCES ON PERSONS AND PROPERTY ARE MATERIAL
prosecution in criminal reckless imprudence resulting in homicide and damage to
ONLY TO DETERMINE THE PENALTY) property

FACTS: Following a vehicular collision in August 2004, petitioner Jason Ivler was
charged before the Metropolitan Trial Court of Pasig City (MeTC), with two
1) Reckless Imprudence is a Single Crime; its Consequences on Persons and
separate offenses: (1) reckless imprudence resulting in slight physical injuries for
Property are Material Only to Determine the Penalty
injuries sustained by respondent Evangeline L. Ponce; and (2) reckless imprudence
resulting in homicide and damage to property for the death of respondent Ponce’s
husband Nestor C. Ponce and damage to the spouses Ponce’s vehicle.
Quasi-offenses penalize “the mental attitude or condition behind the act, the
dangerous recklessness, lack of care or foresight, the imprudencia punible,” unlike
willful offenses which punish the intentional criminal act. These structural and
Crimes charged: 1) reckless imprudence resulting in slight physical injuries; and 2)
conceptual features of quasi-offenses set them apart from the mass of intentional
reckless imprudence resulting in homicide and damage to property
crimes.

On September 7, 2004, Ivler pleaded guilty to the charge in reckless imprudence

resulting in slight physical injuries and was meted out the penalty of public censure. PEOPLE VS OPERANA (A CASE OF EXHUMATION AND AUTOPSY)
Invoking this conviction, Ivler moved to quash the Information of reckless
Facts: Accused was lawfully married to the deceased and was charged of acts
imprudence resulting in homicide and damage to property for placing him in
constituting the crime of parricide with the mother of the deceased as the
jeopardy of second punishment for the same offense of reckless imprudence.
complainant.

MeTC: denied the motion to quash
RTC: denied Ivler’s Petition for Certiorari in dismissing his Motion to Quash
ISSUE: Whether or not Ivler’s constitutional right under the Double Jeopardy Clause
bars further proceedings in the information charging him with reckless imprudence
resulting in homicide and damage to property (YES)
Accused was arraigned and entered a not guilty plea. By reason of the
circumstantial evidence attending the commission of the crime, the accused was
found guilty by the trial court.
Hence, this appeal is set before the Court. The Sol Gen recommended the
imposition of reclusion perpetua in lieu of the death penalty.
Issues: WON the lower court erred in convicting the accused-appellant on
the basis of circumstances that have not been proved beyond reasonable doubt;

Defense: Ivler argues that his constitutional right not to be placed twice in jeopardy
of punishment for the same offense bars his prosecution in reckless imprudence
resulting in homicide and damage to property having been previously convicted in
reckless imprudence resulting in slight physical injuries for injuries for the same
offense. Ivler submits that the multiple consequences of such crime are material
only to determine his penalty
WON the lower court erred in not allowing the children of the accused to testify for
the defense; and
WON the lower court erred in not properly appreciating the autopsy and
exhumation reports that tend to support the suicide theory.
Decision: 1. The decision of the lower court is not only exhaustive but was also
factually and legally sound and sustainable. It is the quality of the circumstances,
not the quantity, that will draw the line on whether the circumstances presented
consists of unbroken chain that will lead to the conclusion that the accused is guilty
without an iota of doubt. Moral certainty is sufficient or that certainty which
produces conviction in an unprejudiced mind.
2. The lower court did not err in not allowing the testimonies of his children. The
question as to the competence of a child to testify is addressed to the sound
discretion of the trial court.
3. The Court agrees with the lower court that the wounds of the deceased would
not have been self-inflicted. The difference of asphyxia by hanging and asphyxia by
strangulation and the findings have supported the fact that the deceased died
involuntarily.
The judgement of conviction is affirmed with the modification of the penalty
recommended by the Sol Gen.
PAL VS PADILLA (AIRPLANE CRASHES)
Facts: A PAL airplane crashed in Mindoro, killing all its passengers. Among them
was Nicanor Padilla, son of Natividad Padilla. As a result of her son’s death,
Natividad filed a complaint against PAL, demanding damages.
Issue: WON the life expectancy of the heirs is the one to be considered in
calculating the damages to be paid by PAL, not the life expectancy of the deceased.
Held: SC ruled that it should be the life expectancy of the deceased, in accordance
with Article 1764 and Article 2206 (1) of the Civil Code, the award of damages for
death is computed on the basis of the life expectancy of the deceased, not of his
beneficiary.
DE VILLA VS DIRECTOR OF NEW BILIBID PRISONS (A DNA RESULT
DENIED ADMISSION BY THE PHILIPPINE SUPREME COURT)
FACTS: By final judgment, petitioner de Villa, the trial court found petitioner guilty
of the rape of Aileen Mendoza when she was 12 years old, his niece by affinity and
was sentenced to suffer the penalty of reclusión perpetua; and ordered him to pay
the offended party civil indemnity, moral damages, costs of the suit, and support
for Leahlyn Corales Mendoza, the putative child born of the rape. Petitioner is
currently serving his sentence at the New Bilibid Prison, Muntinlupa City.
Petitioner’s defense, at the time of the alleged rape, he was already 67 years old.
Old age and sickness had rendered him incapable of having an erection. On
automatic review, the court found that the date of birth of Aileen’s child was
medically consistent with the time of the rape.
Three years after the promulgation of our Decision, there was a question of
Reynaldo de Villa’s guilt or innocence. Petitioner-relator in this case, June de Villa,
is the son of Reynaldo. He alleges that during the trial of the case, he was unaware
that there was a scientific test that could determine once and for all if Reynaldo
was the father of the victim’s child, Leahlyn. Petitioner-relator was only informed
during the pendency of the automatic review of petitioner’s case that DNA testing
could resolve the issue of paternity. This information was apparently furnished by
the Free Legal Assistance Group (FLAG) Anti-Death Penalty Task Force, which took
over as counsel for petitioner. Thus, petitioner’s brief in People v. de Villa sought
the conduct of a blood type test and DNA test in order to determine the paternity
of the child allegedly conceived as a result of the rape and the relief was implicitly
denied. Petitioner filed a Motion for Partial Reconsideration of the Decision,
wherein he once more prayed that DNA tests be conducted and it was denied with
finality in a Resolution. Petitioner-relator was undaunted by these challenges, for
having been informed that DNA tests required a sample that could be extracted
from saliva, petitioner-relator asked Billy Joe de Villa, a grandson of Reynaldo de
Villa and a classmate of Leahlyn Mendoza, to ask Leahlyn to spit into a new, sterile
cup and used as a sample. Petitioner-relator then gathered samples from four
grandchildren of Reynaldo de Villa. Petitioner-relator requested the NSRI to
conduct DNA testing on the sample given by Leahlyn Mendoza, those given by the
grandchildren of Reynaldo de Villa, and that given by Reynaldo de Villa himself. The
identities of the donors of the samples, save for the sample given by Reynaldo de
Villa, were not made known to the DNA Analysis Laboratory.
After testing, the DNA Laboratory rendered a preliminary report and showed that
Reynaldo de Villa could not have sired any of the children whose samples were
tested, due to the absence of a match between the pertinent genetic markers.
ISSUE:
Whether or not the DNA result is a valid basis for habeas corpus and new trial?
HELD:
No. The most criterion for the issuance of the writ of habeas corpus, is that the
individual seeking such relief be illegally deprived of his freedom of movement or
placed under some form of illegal restraint. If an individual’s liberty is restrained via
some the legal process, the writ of habeas corpus is unavailing. In the recent case
of Feria v. CA, it was held that review of judgment of conviction is allowed in a
petition for the issuance of the writ of habeas corpus only in a very specific
instances, such as when, as a consequence of a judicial proceeding, (a) there has
been a deprivation of a constitutional right resulting in the restraint of a person; (b)
the court had no jurisdiction to impose the sentence; or (c) an excessive penalty
has been imposed, as such sentence is void as to such excess. This court stated the
general rule that the writ of habeas corpus is not a writ of error, and should not be
thus used.
A motion for new trial based on newly-discovered evidence may be granted only if
the following requisites are met: (a) that the evidence was discovered after trial; (b)
that said evidence could not have been discovered and produced at the trail even
with the exercise of reasonable diligence; (c) that it is material, not merely
cumulative, corroborative or impeaching; and (d) that the evidence is of such
weight that, if admitted, it would probably change the judgment.
Petitioner-relator’s claim that he was “unaware” of the existence of DNA testing
until the trial was concluded carries no weight with this court. Lack of knowledge of
the existence of DNA testing speaks of negligence, either on the part of petitioner,
or on the part of petitioner’s counsel. In either instance, however, this negligence is
binding upon petitioner.
PEOPLE VS UMAWID (DEFENSE OF INSANITY)
Facts: Umawid set up the defense of insanity when he attacked and killed with a
Panabas a 2-yr old child and subsequently his own nephew whose fingers were
amputated. However, the doctor he presented said that he was manifesting
psychotic symptoms he could not tell with certainty whether Umawid was
psychotic at the time of the commission of the crimes.
Issue:
Whether or not the accused is exempted from criminal liablity due to insanity?
Ruling:
No. Under Article 12 of the RPC:
Article 12. Circumstances which exempt from criminal liabity - The following are
exempt from criminal liability:
1. An imbecile or an insane person, unless the latter has acted during a lucid
interval.
The defense of insanity is in the nature of confession and avoidance because an
accused invoking the same admits to have committed the crime but claims that he
or she is not guilty because of insanity. The presumption is in favor of sanity,
anyone who pleads the said defense bears the burden of proving it with clear and
convincing evidence. Considering the case, the evidence must relate to the time
immediately before or during the commission of the offense/s with which one is
charged. Also, to support the defense of insanity, it must be shown that the
accused had no full and clear understanding of the nature and consequences of his
or her acts.
In this case, Umawid relied solely on the defense of Dr. Quincina and Dr. Juliana to
support his claim of insanity. However, Dr. Quincina only examined Umawid six
months before he committed the crime and three months and four months
thereafter. Her findings as she admitted did not include Umawid's mental
disposition immediately before or during the commission of the crimes. Also, given
that Dr. Juliana failed to testify in favor of the accused, Umawid's defense of
insanity remained unsubstiantiated, hence, he was properly adjudged by the RTC
and CA as criminally liable.
VENTURA VS SAMSON (CASE OF A PROFESSIONAL COMMITTING
RAPE)
From the undisputed facts gathered from the evidence and the admissions of
respondent himself, we find that respondent’s act of engaging in sex with a young
lass, the daughter of his former employee, constitutes gross immoral conduct that
warrants sanction. Respondent not only admitted he had sexual intercourse with
complainant but also showed no remorse whatsoever when he asserted that he did
nothing wrong because she allegedly agreed and he even gave her money. Indeed,
his act of having carnal knowledge of a woman other than his wife manifests his
disrespect for the laws on the sanctity of marriage and his own marital vow of
fidelity. Moreover, the fact that he procured the act by enticing a very young woman
with money showed his utmost moral depravity and low regard for the dignity of the
human person and the ethics of his profession.

Respondent has violated the trust and confidence reposed on him by complainant,
then a 13-year-old minor, who for a time was under respondent’s care. Whether the
sexual encounter between the respondent and complainant was or was not with the
latter’s consent is of no moment. Respondent clearly committed a disgraceful,
grossly immoral and highly reprehensible act. Such conduct is a transgression of the
standards of morality required of the legal profession and should be disciplined
accordingly. Respondent is disbarred from the practice of law.

DELA CRUZ VS PEOPLE (DRUG CASE JURISPRUDENCE)

FACTS:
Complainants alleged that a certain Ariel Escobedo was picked up by several
unknown male persons believed to be police officers for allegedly selling drugs.
Complainants were instructed to proceed to the Gorordo Police Station. They met
“James” at the Police Station, who demanded from them P100,000.00 which was
later lowered to P40,000.00, in exchange for the release of Ariel.

The accused was nabbed after an entrapment operation was conducted. The
accused was later brought to the forensic laboratory where he was required to
submit his urine for drug testing. The test yielded a positive result for presence of
dangerous drugs.

ISSUE:
Whether or not the drug test conducted upon the petitioner is legal. (NO)

HELD:
The drug test in Section 15 does not cover persons apprehended or arrested for
any unlawful act, but only for unlawful acts listed under Article II of the law.

The drug test was in violation of the petitioner’s right to privacy and right against
self-incrimination. It is incontrovertible that petitioner refused to have his urine
extracted and tested for drugs.