The People of the Phil. Island, plaintiff-appellant plaintiff-appellant vs Wong Cheng (alias Wong Chun),defendant-appellee Chun),defendant-appellee Facts: The appellant, in representation of the Attorney General filed an appeal that urges the revocation of a demurrer sustained by the Court of First Instance of Manila presented presented by the defendant. defendant. The defendant, defendant, accused accused of having having illegally illegally smoked opium, opium, aboard aboard the merchant merchant vessel vessel Changsa Changsa of English English nationality nationality while the said vessel was anchored in Manila Bay two and a half miles from the shores of the city. In the said demurrer the defendant contended the lack of jurisdiction of the lower court of the said crime, which resulted to the dismissal of the case. Issue: Whether or not the Philippine courts has jurisdiction over the crime committed by Wong Cheng aboard merchant vessels anchored in our jurisdiction waters? Held: Yes. The crime on the case at bar was was committed in our internal internal waters thus thus having our court the right of jurisdiction jurisdiction over the offense offense committed. The court said “Having the opium smoked within our territorial limits, even though aboard a foreign merchant ship, is a breach of the public order, because it causes such drugs to produce pernicious pernicious effects within our territory”. Therefore, the demurrer demurrer is revoked revoked and court ordered further proceedings proceedings
The People of the Philippine Island, plaintiff-appellee plaintiff-appellee vs. Francisco Sara, defendant-appelant defendant-appelant
Facts: On August 2, 1930, Francisco Sara was out to shoot birds. At the same Gabriel Catapang and his wife Ruperta Mendoza were out collecting bananas. A gunshot was heard and hit Gabriel Catapang. The gunshot came from Francisco Sara hitting Gabriel in the right lower part of the abdomen. Death followed as a result of the wound. The accused contended, “seeing a bird sitting on the tree, raised his gun intending to shoot when Gabriel Catapang approached and asked that he be permitted to shoot the bird, at the same time seizing the barrel of the gun and pulling it around towards his own body. As the accused at this moment has his finger on the trigger, the weapon was discharge and Gabriel receives the load at his abdomen. Upon seeing Gabriel fall, he seized with fright and ran away”. Issue: Whether or not Francisco Sara if guilty of homicide? Held: No. The killing was not intentionally committed thus the Supreme Court held that the homicide should be attributed at least to the reckless and imprudent act of the accused in handling and discharging the weapon in his hands. Therefore, the accused is not guilty of homicide but instead guilty of homicide by reckless imprudence.
The People of the Philippines, plaintiff-appellee, Vs Loreto Renegado y Senora, accused-appallent
Facts: Loreto Renagado was a schools clerk at Tiburcio Tancinco Memorial Vocational Schools located in the City of Calbayog. As a school clerk Renegado was tasked to the following duties: a. To type correspondence, memorandum, circulars of the Head of the School, b. To help type test questions of teachers for every periodical test, c. To help type reports of the schools, d. To help type handout of the teachers, e. To file and account records of the school, e. To mail some reports. Since the periodical test is coming, Mamerto de Lira, a school teacher, requested Loreto Renagado to type the stencil of his test questions. Renegado refuses for according to him he still had much work to do in the principal’s office and that typing test questions wasn’t among his duties. However, Lira reminded Renegado of the instructions of the principal that he could be asked by teachers to type the test questions especially if the teacher concerned had no knowledge on typing, and finishing his remark stating: “you can finish your work if you will sit down and work.” This remark makes Renegado angry. On August 29, past 9:00, Lira went to the school canteen and ordered a bottle of pepsi cola. At about 9:30 while Lira was drinking his pepsi cola Renegado entered the canteen seeing Lira with his back towards him, he immediately and without warning stabbed Lira with a knife which caused Lira’s death. Witnesses from the prosecution gave their statement against the accused and testimonies from the defense were also heard. The defense tried to convince the court that the accused has a mental condition or mentally ill when the incident happened. Therefore, according to the defense the accused must be exempt from criminal liability. Issue: Whether or not the accused Loreto Renegado should be excused from criminal liability? Held: No. The basic principle of criminal law shall apply, viz: that a person is criminally liable for a felony committed by him; that a felonious act is presumed to have been done with criminal intent, that is, with freedom, intelligence and malice because the moral and legal presumption is that freedom and intelligence constitute the normal condition of a person in the absence of evidence in the contrary, that one of the causes which will overthrow thus presumption of voluntariness and intelligence is insanity in which the actor is exempt from criminal liability as provided by the law. Thus, the one who invokes insanity as an exempting circumstance must prove it clearly and must have a positive evidence. In which the defense fails to prove. Hence, the Supreme Court affirmed the conviction of the accused-appellant Loreto Renegado. The United States, plaintiff-appellee Vs Ah Chong, defendant-appellant Facts:
Ah Chong was a cook in Ft. McKinley. He was afraid of bad elements. One evening, before going to bed, he locked himself in his room by placing a chair against the door. After having gone to bed, he was awakened by someone trying to open the door. He called out twice, “Who is there,” but received no answer. Fearing that the intruder was a robber, he leaped from his bed & called out again, “If you enter the room I will kill you.” But at that precise moment, he was struck by the chair that had been placed against the door, & believing that he was being attacked he seized a kitchen knife & struck & fatally wounded the intruder who turned out to be his roommate. Issue: Whether or not Ah Chong is guilty of murder? Held: No. Ah Chong was not held liable for the death of his roommate. The principle of mistake of fact shall apply to the case. The court was convinced that he acted in good faith, without malice, or criminal intent, in the belief that that he was doing no more than exercising his legitimate right to self-defense; that had the facts been as he believed them to be he would have been wholly exempt from criminal liability on account of his act; and that he cannot be said to have been guilty of negligence or imprudence or even carelessness in falling into his mistake as to the facts, or the means adopted by him to defend himself from imminent danger which he believed threatened his person and his property and the property under his charge. Hence, the Supreme Court reversed the conviction imposed by the trial court, and the defendant acquitted from the crime of murder.
