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Padillo vs. People

9th October 2024

ak536847
G.R. No. 271012
Summary
Roel Padillo was charged with illegal possession of dangerous drugs (shabu) found during the execution of a search warrant at his residence. The Regional Trial Court (RTC) convicted him, and the Court of Appeals (CA) affirmed the conviction. The Supreme Court, upon review, reversed the lower courts' decisions and acquitted Padillo, finding fatal defects in both the issuance and implementation of the search warrant, rendering the seized evidence inadmissible, and also noting a significant, unexplained gap in the chain of custody of the alleged drugs.
Background
The Philippine Drug Enforcement Agency (PDEA) suspected Roel Padillo of possessing shabu at his residence in Balingoan, Misamis Oriental, prompting them to apply for and obtain a search warrant to search the premises.
Criminal Law II

People vs. ABC260708

23rd January 2024

ak737802
G.R. No. 260708
Summary
This case involves an appeal by ABC260708 who was convicted by the Regional Trial Court (RTC) and the Court of Appeals (CA) for the rape (Criminal Case No. 17006) and rape through sexual assault (Criminal Case No. 17007) of his minor daughter, AAA260708. The Supreme Court affirmed the conviction but delved into the proper legal nomenclature when elements of both statutory rape (victim below 12 years old) and qualified rape (minority and relationship) are present. The Court abandoned the term "qualified statutory rape" used in some prior jurisprudence, ruling that the correct designation is "qualified rape of a minor," and established guidelines for its application. The damages awarded in the qualified rape case were also modified upwards.
Background
The case arose from charges filed against the accused, ABC260708, for committing rape through carnal knowledge and rape through sexual assault (oral rape) against his own daughter, AAA260708, who was eight years old at the time of the incidents in March 2015.
Criminal Law II
Rape

People vs. Flores

11th October 2023

ak680841
G.R. No. 262686
Summary
This is a drug case where the Supreme Court reversed the conviction of the accused-appellants for illegal sale and possession of dangerous drugs due to reasonable doubt. The Court found significant breaches in the chain of custody of the seized drugs, particularly regarding the insulating witnesses' presence and the unexplained inconsistencies in the inventory process, thus undermining the integrity of the evidence and upholding the constitutional presumption of innocence.
Background
Accused-appellants were apprehended in a buy-bust operation for allegedly selling and possessing methamphetamine hydrochloride (shabu). The Regional Trial Court (RTC) convicted them, and the Court of Appeals (CA) affirmed with slight modification. The case reached the Supreme Court via a Notice of Appeal. Accused-appellant Truelen passed away during the appeal process.
Criminal Law II

Nisperos vs. People

29th November 2022

ak942626
G.R. No. 250927
Summary
This case involves Mario Nisperos y Padilla, who was convicted of selling dangerous drugs in a buy-bust operation. The Supreme Court reversed the conviction, holding that the buy-bust team unjustifiably deviated from the chain of custody rule by failing to ensure the presence of all required witnesses at the place of transaction for the immediate inventory after seizure, leading to reasonable doubt about the integrity of the seized drugs.
Background
Petitioner Mario Nisperos y Padilla was charged with selling methamphetamine hydrochloride (shabu) in a buy-bust operation. The prosecution presented evidence of a pre-arranged buy-bust conducted by police officers based on information from a confidential informant. The defense contested the legality of the operation, particularly the chain of custody of the seized drug.
Criminal Law II

People vs. Agao

4th October 2022

ak513960
930 Phil. 559 , G.R. No. 248049
Summary
This case involves an appeal from a conviction for two counts of statutory rape where the accused-appellant, the victim's stepfather, contended that the acts did not constitute consummated rape. The Supreme Court affirmed the conviction with modification (one count statutory rape, one count simple rape) but took the opportunity to definitively clarify the anatomical threshold distinguishing attempted from consummated rape by penile penetration, holding that penetration of the vulval cleft (cleft of the labia majora), however slight, constitutes consummation.
Background
The case arose from allegations of repeated sexual abuse committed by the accused-appellant, Efren Agao, against his minor stepdaughter, AAA, starting when she was 10 years old in 2009/2010 and continuing until 2012. Agao lived with AAA and her mother, BBB. The specific charges relate to incidents in July 2010 and January 2012.
Criminal Law II
Rape

Calleja vs. Executive Secretary

7th December 2021

ak549249
G.R. No. 252578
Summary
Petitioners challenged the constitutionality of the Anti-Terrorism Act of 2020 (ATA), alleging violations of free speech, due process, and other rights. The Supreme Court partially granted the petitions, striking down specific provisions as unconstitutional, including parts of Section 4 (definition of terrorism) and Sections 25 (designation powers of the Anti-Terrorism Council), while upholding most of the law.
Background
The Anti-Terrorism Act of 2020 (ATA) was enacted to replace the criticized Human Security Act of 2007, aiming to strengthen counter-terrorism measures and align with international standards (e.g., UN protocols, FATF guidelines). Civil society groups, journalists, and activists filed petitions arguing the law’s vague definitions (e.g., “terrorism,” “inciting”) and expanded executive powers threatened constitutional rights, enabling state abuse through arbitrary designations and surveillance. The government asserted the law was necessary to address evolving threats from groups like Abu Sayyaf and communist rebels while avoiding international sanctions for non-compliance with anti-terrorism financing rules. The case emerged amid heightened polarization over national security policies and concerns over “red-tagging” practices linking dissenters to terrorism.
Constitutional Law I Constitutional Law II Criminal Law II

Ridao vs. Handmade Credit and Loans, Inc.

3rd February 2021

ak229915
895 Phil. 554 , G.R. No. 236920
Summary
This case involves a petition for review on certiorari assailing the Court of Appeals' decision which ordered Gemma Ridao to pay Handmade Credit and Loans, Inc. an alleged outstanding loan balance. Ridao claimed full payment, supported by a ledger, while Handmade Credit contested the ledger's later entries and relied on promissory notes that were later found to be materially altered. The Supreme Court granted Ridao's petition, dismissing Handmade Credit's complaint, holding that once the debtor presents evidence of payment, the burden shifts to the creditor to prove non-payment, which Handmade Credit failed to do, especially given the invalidity of its altered promissory notes.
Background
Petitioner Gemma A. Ridao obtained loans from respondent Handmade Credit and Loans, Inc., represented by Ridao's brother-in-law, Teofilo Manipon. A dispute arose when Handmade Credit claimed Ridao failed to pay her obligations, including an alleged increased dollar loan and an additional peso loan, while Ridao asserted she had fully paid the admitted $4,300.00 loan obligation.
Criminal Law II

People vs. Meneses

30th June 2020

ak504298
940 SCRA 372 , 875 Phil. 724 , G.R. No. 233533
Summary
This case involves the appeal of Joey Meneses y Cano, who was convicted of illegal sale of dangerous drugs. The Supreme Court affirmed the lower courts' decisions, finding that the prosecution successfully proved all elements of the crime through a valid buy-bust operation, the testimonies of police officers, and the presentation of the seized drugs as evidence. The Court rejected Meneses' defenses of denial and frame-up, upholding the conviction.
Background
Joey Meneses was apprehended in a buy-bust operation conducted by police officers after a confidential informant reported his drug dealing activities. The operation stemmed from an initial transaction where Meneses sold marijuana to an undercover police officer. Subsequently, a planned buy-bust operation led to his arrest for selling both marijuana and shabu.
Criminal Law II

People vs. Guillermo

27th November 2019

ak963268
926 SCRA 144 , 866 Phil. 690 , G.R. No. 229515
Summary
This case involves the appeal of Nida and Desiree Guillermo's conviction for illegal sale of dangerous drugs. The Supreme Court reversed the Court of Appeals and Regional Trial Court decisions, acquitting the accused due to reasonable doubt arising from questionable aspects of the buy-bust operation and serious lapses in the chain of custody of the seized drugs.
Background
Nida and Desiree Guillermo were arrested in a buy-bust operation for allegedly selling shabu to a poseur-buyer. They were charged with violation of Section 5, in relation to Section 26, Article II of R.A. 9165. The prosecution presented the testimony of the arresting officers and the forensic chemist, while the defense presented testimonies denying the drug sale and alleging irregularities in the arrest and post-arrest procedures.
Criminal Law II

People vs. Tulagan

12th March 2019

ak362964
896 SCRA 307 , 849 Phil. 197 , G.R. No. 227363
Summary
This case involves an appeal affirming Salvador Tulagan's conviction for sexual assault and statutory rape against a nine-year-old minor, AAA. The Supreme Court upheld the conviction but modified the nomenclature of the sexual assault charge, the penalty imposed for it, and the damages awarded for both crimes, using the opportunity to extensively clarify and reconcile the applicable provisions of the Revised Penal Code (RPC) and Republic Act No. 7610 (Special Protection of Children Against Abuse, Exploitation and Discrimination Act) concerning sexual offenses against minors, particularly addressing the interplay between RPC Articles 266-A, 266-B, 336 and Section 5(b) of R.A. No. 7610, establishing applicable penalties and standardized damages based on prevailing jurisprudence.
Background
The case arose from two separate incidents where the accused-appellant, Salvador Tulagan, sexually abused his nine-year-old neighbor, AAA, first by inserting his finger into her vagina in September 2011, and later by having sexual intercourse with her in October 2011, leading to charges of sexual assault and statutory rape respectively.
Criminal Law II
Rape

People vs. Noah

6th March 2019

ak526523
895 SCRA 399 , 848 Phil. 680 , G.R. No. 228880
Summary
This case involves Lina Achieng Noah, a Kenyan national, who was convicted of illegal transportation of dangerous drugs (methamphetamine hydrochloride or shabu). The Supreme Court affirmed the Court of Appeals' decision, which upheld the Regional Trial Court’s conviction. The core issue revolved around the legality of the warrantless search at the airport and the integrity of the chain of custody of the seized drugs. The Court ruled in favor of the prosecution, finding that the chain of custody was properly established and Noah's guilt was proven beyond reasonable doubt.
Background
Lina Achieng Noah was apprehended at Ninoy Aquino International Airport Terminal 1 upon arrival from Kenya via Dubai. Customs Examiner Landicho became suspicious of her luggage, leading to a further inspection in an exclusion room. This inspection revealed packages of shabu concealed within a laptop bag inside her luggage. Noah claimed the luggage was given to her and denied knowledge of the drugs.
Criminal Law II

People vs. Suico

10th September 2018

ak454553
880 SCRA 32 , 840 Phil. 1 , G.R. No. 229940
Summary
The Supreme Court affirmed the conviction of Jimboy Suico y Acope for illegal transportation of dangerous drugs (marijuana). The Court upheld the validity of the warrantless arrest and seizure, and found that the prosecution sufficiently established the chain of custody of the seized drugs, proving his guilt beyond reasonable doubt.
Background
Police officers set up a checkpoint for a "no plate, no travel" policy based on information about a person transporting marijuana on a specific motorcycle. Jimboy Suico, matching the description, approached the checkpoint and attempted to evade it, leading to his arrest and the discovery of marijuana in his backpack and sack.
Criminal Law II

People vs. Romy Lim y Miranda

4th September 2018

ak331437
839 Phil. 598 , G.R. No. 231989
Summary
Romy Lim y Miranda was convicted by the RTC and CA for illegal sale and possession of shabu (Sections 5 and 11, R.A. 9165) stemming from a buy-bust operation conducted by PDEA agents. Lim appealed to the Supreme Court, primarily arguing that the prosecution failed to establish the chain of custody over the seized drugs as mandated by Section 21 of R.A. 9165 due to the absence of required witnesses during the inventory. The Supreme Court found merit in Lim's argument, holding that the arresting officers failed to comply with the mandatory witness requirements under Section 21 without providing justifiable grounds, thereby casting reasonable doubt on the integrity of the seized drugs (corpus delicti), reversed the lower courts' decisions, acquitted Lim, and established a new mandatory policy for prosecutors regarding compliance with Section 21.
Background
Following a tip from a confidential informant (CI) regarding alleged drug selling activities by "Romy" in Cagayan de Oro City, agents from the Philippine Drug Enforcement Agency (PDEA) Regional Office X planned and executed a buy-bust operation targeting the accused-appellant, Romy Lim y Miranda, at his residence.
Criminal Law II

People vs. Tomawis

18th April 2018

ak721106
862 SCRA 131 , 830 Phil. 385 , G.R. No. 228890
Summary
Basher Tomawis was convicted of selling illegal drugs. The Supreme Court reversed the conviction, finding that the prosecution failed to prove his guilt beyond reasonable doubt due to significant procedural lapses in the handling of the seized drugs, particularly regarding the chain of custody and compliance with the mandatory witness rule under Section 21 of RA 9165. The Court emphasized the importance of strict adherence to these procedures to protect the integrity of drug evidence and safeguard the rights of the accused.
Background
This is a criminal case involving the illegal sale of dangerous drugs, specifically methamphetamine hydrochloride (shabu), under Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002. The case originated from a buy-bust operation conducted by the Philippine Drug Enforcement Agency (PDEA). The central issue revolves around the procedural compliance of law enforcement in handling seized drug evidence and protecting the accused’s rights within the context of the anti-drug campaign.
Criminal Law II

Osorio vs. Navera

26th February 2018

ak626610
856 SCRA 435 , 826 Phil. 643 , G.R. No. 223272
Summary
The Supreme Court ruled that kidnapping can never be part of a soldier's official functions and cannot be done in a soldier's official capacity. If a soldier proceeds with kidnapping, even allegedly under orders from a superior officer, they shall be tried before civil courts. The remedy of habeas corpus, arguing that only courts-martial have jurisdiction over Armed Forces members, will not apply.
Background
The case stems from the alleged kidnapping of two University of the Philippines students, Karen E. Empeño and Sherlyn T. Cadapan, by military personnel including SSgt. Osorio and Major General Jovito Palparan. The victims were reportedly abducted from a house in Hagonoy, Bulacan, and detained in various military facilities from June 2006 to July 2007, resulting in their continuing disappearance.
Criminal Law II

People vs. Amarela

17th January 2018

ak555521
852 SCRA 54 , 823 Phil. 1188 , G.R. Nos. 225642-43
Summary
This case is an appeal to the Supreme Court challenging the Court of Appeals' decision which affirmed the Regional Trial Court's conviction of Juvy Amarela and Junard Racho for two separate counts of rape against the same victim, AAA, on consecutive days. The Supreme Court reversed the lower courts' decisions and acquitted both accused-appellants due to the prosecution's failure to prove their guilt beyond reasonable doubt, citing significant inconsistencies and improbabilities in the complainant's testimony and the lack of sufficient corroborating evidence.
Background
The case arose from allegations that Juvy Amarela raped AAA on February 10, 2009, and that Junard Racho raped her hours later, in the early morning of February 11, 2009, in Davao City, during fiesta celebrations. Two separate Informations for rape were filed against Amarela and Racho, respectively, which were jointly tried.
Criminal Law II
Rape

De Lima vs. Guerrero

10th October 2017

ak175936
843 SCRA 1 , 819 Phil. 616 , G.R. No. 229781
Summary
This case is a Petition for Certiorari and Prohibition filed by Senator Leila De Lima, assailing orders issued by Judge Juanita Guerrero of the Regional Trial Court (RTC) of Muntinlupa City, Branch 204, related to a criminal case filed against De Lima for violation of drug laws. The Supreme Court ultimately dismissed the petition, finding it premature and violative of the hierarchy of courts and the rule against forum shopping, and upheld the jurisdiction of the RTC.
Background
Legislative inquiries into drug syndicates at the New Bilibid Prison led to complaints against Senator De Lima for illegal drug trading. These complaints were consolidated before the Department of Justice (DOJ) Panel of Prosecutors for preliminary investigation. De Lima challenged the DOJ Panel's jurisdiction, arguing that the Ombudsman had exclusive jurisdiction.
Criminal Law II

Integrated Bar of the Philippines Pangasinan Legal Aid vs. Department of Justice

25th July 2017

ak758754
832 SCRA 36 , 814 Phil. 440 , G.R. No. 232413
Summary
The Supreme Court ruled that detainees held beyond mandated periods for preliminary investigation or whose dismissed cases remain pending automatic review must be released to protect constitutional rights to liberty, even if DOJ circulars initially permitted prolonged detention.
Background
The Integrated Bar of the Philippines (IBP) discovered pre-trial detainees languishing in jail for years without charges due to DOJ circulars requiring automatic reviews. Jay-Ar Senin, arrested in a 2015 drug buy-bust, waived Article 125 of the RPC, but his case was dismissed and remained under DOJ review for eight months.
Criminal Law II

People vs. Jumawan

21st April 2014

ak373008
722 SCRA 108 , 733 Phil. 102 , G.R. No. 187495
Summary
Accused-appellant Edgar Jumawan was convicted by the Regional Trial Court (RTC) and the Court of Appeals (CA) for two counts of raping his wife, KKK, on October 16 and 17, 1998. Jumawan appealed to the Supreme Court, primarily arguing against the concept of marital rape, asserting implied consent within marriage, and raising the defense of alibi. The Supreme Court affirmed the conviction, emphasizing that R.A. No. 8353 (Anti-Rape Law of 1997) explicitly removed marital immunity for rape, thereby rejecting the outdated doctrine of irrevocable implied consent. The Court found the victim's testimony credible and corroborated by her daughters, deemed the appellant's alibi insufficient, and upheld the penalty of *reclusion perpetua* for each count, with modifications only to the civil damages awarded.
Background
The accused-appellant, Edgar Jumawan, and the private complainant, KKK, were married in 1975, raised four children, and established several businesses primarily managed by KKK. While their conjugal intimacy was initially fulfilling, the accused-appellant reportedly became sexually brutal starting in 1997, foregoing foreplay and causing physical pain, leading KKK to resist, which resulted in threats. In 1998, quarrels increased, often initiated by the accused-appellant complaining about KKK's preoccupation with their businesses' financial problems and her alleged failure to attend to him, stating a woman's place was at home and in bed.
Criminal Law II
Rape

Bongalon vs. People

20th March 2013

ak835327
694 SCRA 12 , 707 Phil. 11 , G.R. No. 169533
Summary
This case involves a petitioner convicted by the Regional Trial Court (RTC) and the Court of Appeals (CA) for child abuse under Republic Act No. 7610 for striking and slapping a minor. The Supreme Court, despite procedural lapses in the petition, reviewed the case on its merits, set aside the conviction for child abuse, and found the petitioner guilty only of slight physical injuries under the Revised Penal Code, applying the mitigating circumstance of passion or obfuscation. The Court emphasized that not every act of physical contact against a child constitutes child abuse; specific intent to debase, degrade, or demean the child's intrinsic worth must be proven beyond reasonable doubt.
Background
The incident occurred during an evening procession where the petitioner's minor daughters and the victim, Jayson dela Cruz (a 12-year-old minor), along with his brother, were participants or bystanders. An initial altercation involving alleged stone-throwing and name-calling between the children preceded the petitioner's confrontation with Jayson.
Criminal Law II
Slight Physical Injuries

People vs. Trestiza

16th November 2011

ak906974
660 SCRA 407 , 676 Phil. 420 , G.R. No. 193833
Summary
A case involving the kidnapping for ransom of Lawrence Yu and Irma Navarro by police officers and a private individual who initially claimed they were conducting a legitimate drug operation. The Supreme Court affirmed the conviction of the accused for kidnapping with ransom despite their being police officers.
Criminal Law II

Jacinto vs. People

13th July 2009

ak482641
610 Phil. 100 , G.R. No. 162540
Summary
Petitioner Gemma T. Jacinto, a collector for Mega Foam International Inc., was charged with Qualified Theft for allegedly taking a customer's check payment of P10,000.00 and depositing it into her brother-in-law's account. The check was subsequently dishonored. The Regional Trial Court (RTC) and the Court of Appeals (CA) found her guilty of Qualified Theft. The Supreme Court modified the judgment, finding Jacinto guilty only of an Impossible Crime, reasoning that since the check was worthless at the time of taking (as it was later dishonored), the crime of theft could not be consummated due to factual impossibility.
Background
The case originated from an employer-employee relationship where the petitioner, a collector for Mega Foam International Inc., was entrusted with receiving payments from customers. The dispute arose when a check payment collected by the petitioner was not remitted to the company but was instead deposited into an account linked to her family and was subsequently dishonored, leading to accusations of theft with grave abuse of confidence.
Criminal Law II
Impossible Crime

Soria vs. Desierto

31st January 2005

ak603974
450 SCRA 339 , 490 Phil. 749 , G.R. Nos. 153524-25
Summary
The Supreme Court affirmed the Ombudsman's dismissal of a complaint for violation of Article 125 of the Revised Penal Code (Delay in the delivery of detained persons) against police officers, holding that Sundays, holidays, and election days are excluded in computing the period within which arrested persons should be delivered to judicial authorities.
Criminal Law II

People vs. Comadre

8th June 2004

ak679022
431 SCRA 366 , 475 PHIL. 293 , G.R. No. 153559
Summary
This case involves an automatic review of a Regional Trial Court (RTC) decision convicting Antonio Comadre, George Comadre, and Danilo Lozano of the complex crime of Murder with Multiple Attempted Murder and sentencing them to death. The Supreme Court affirmed the conviction and death sentence only for Antonio Comadre, finding sufficient evidence that he threw the grenade that killed one victim and injured others, qualifying the crime as Murder by means of explosion under Article 248(3) of the Revised Penal Code (RPC) and applying the complex crime rule under Article 48. However, the Court acquitted George Comadre and Danilo Lozano due to insufficient evidence to prove conspiracy, ruling their mere presence at the scene was not enough. The Court also clarified the non-applicability of R.A. 8294 in this instance and modified the awarded damages.
Background
The case arose from an incident where victims were having a drinking session on the terrace of a house when the appellants allegedly stopped in front, and one of them, Antonio Comadre, lobbed a hand grenade onto the roof, which subsequently exploded, causing death and injuries.
Criminal Law II
Murder

People vs. Suzuki

23rd October 2003

ak996295
414 SCRA 43 , G.R. No. 120670
Summary
A case concerning illegal possession of marijuana where the Supreme Court affirmed the conviction but modified the penalty from death to reclusion perpetua, highlighting important principles about airport security searches and constitutional rights against unreasonable searches and seizures.
Background
The case stems from an airport security check at Bacolod Airport where the defendant, a Japanese national, was found in possession of marijuana concealed in a box of "Bongbong's piaya." The case raises important questions about the constitutionality of airport security searches and the rights of individuals against unreasonable searches and seizures.
Criminal Law II

People vs. Quiñanola

5th May 1999

ak891024
306 SCRA 710 , G.R. No. 126148
Summary
This case involves an appeal from a Regional Trial Court decision convicting accused-appellants Agapito Quiñanola and Eduardo Escuadro of frustrated rape. The Supreme Court reviewed the entire case, reiterated that the crime of frustrated rape is non-existent under Philippine law, found the victim's testimony credible despite medico-legal findings of an intact hymen, determined that the slightest penetration (touching of the labia) constitutes consummated rape, established conspiracy between the appellants, and ultimately found both appellants guilty beyond reasonable doubt of two counts of consummated rape, sentencing them to reclusion perpetua for each count.
Background
The case arose from the alleged rape of a 15-year-old girl, Catalina Carciller, by two armed men, Agapito Quiñanola and Eduardo Escuadro, in Dumanjug, Cebu, on the night of March 5, 1994. The appellants allegedly accosted the victim and her companions, separated her from them, and took turns sexually assaulting her at gunpoint.
Criminal Law II
Rape

People vs. Santiano

3rd December 1998

ak138319
299 SCRA 583 , G.R. No. 123979
Summary
The Supreme Court affirmed the conviction of four accused-appellants for kidnapping under Article 267 of the Revised Penal Code, despite their being initially charged with the complex crime of kidnapping with murder. The Court ruled that even when evidence fails to support one component of a complex crime charge, conviction for the other proven offense remains legally feasible.
Criminal Law II

People vs. Catantan

5th September 1997

ak898009
278 SCRA 761 , 344 Phil. 315 , G.R. No. 118075
Summary
This case involves the interpretation of piracy under PD No. 532 (Anti-Piracy and Highway Robbery Law of 1974) versus grave coercion under Article 286 of the Revised Penal Code. The Supreme Court affirmed the conviction of the accused for piracy after he and his companion seized a fishing boat through force and intimidation in Philippine waters.
Background
On June 27, 1993, at around 3:00 AM, the Pilapil brothers were fishing in the seawaters of Tabogon, Cebu, when the accused and his companions approached their boat, boarded it using force and intimidation, and compelled them to ferry them to different locations. The accused later abandoned the victims after transferring to another vessel.
Criminal Law II

People vs. Abarca

14th September 1987

ak372672
153 SCRA 735 , 237 Phil. 718 , No. L-74433
Summary
This case involves Francisco Abarca who, after discovering his wife in the act of sexual intercourse with Khingsley Paul Koh, obtained a rifle and shot Koh dead about an hour later at a mahjong session, inadvertently injuring Arnold and Lina Amparado in the process. The Regional Trial Court convicted Abarca of the complex crime of murder with double frustrated murder and sentenced him to death. The Supreme Court modified the judgment, holding that the killing of Koh fell under Article 247 of the Revised Penal Code (Death Inflicted Under Exceptional Circumstances), resulting in the penalty of *destierro*, and found Abarca liable only for Less Serious Physical Injuries through Simple Imprudence or Negligence for the injuries sustained by the Amparados, imposing the penalty of *arresto mayor*.
Background
The case arose from an illicit relationship between Khingsley Paul Koh and Jenny Abarca, the wife of accused-appellant Francisco Abarca. This relationship began while Francisco Abarca was away in Manila reviewing for the 1983 bar examinations, leaving his wife behind in Tacloban, Leyte.
Criminal Law II
Death or physical injuries inflicted under exceptional circumstances

People vs. Alvero

11th April 1950

ak350120
86 Phil. 58 , No. L-820
Summary
This case involves charges of treason against Aurelio Sevilla Alvero based on his collaboration with Japanese forces during World War II through economic, political, and military activities.
Background
Aurelio Alvero was charged with 22 counts of treason before the People's Court for various collaborative activities with Japanese forces during the occupation of the Philippines in World War II. These activities included business dealings through ASA Trading, membership in pro-Japanese organizations, and military collaboration through groups like MAKAPILI and Bisig Bakal Ng Tagala.
Criminal Law II

People vs. Paar

31st March 1950

ak008848
85 Phil. 864 , No. L-2318
Summary
This case is an appeal from a judgment of the now-defunct People’s Court, which found Teofilo Paar guilty of treason and sentenced him to reclusion perpetua along with a fine of PHP 10,000 and costs. The Supreme Court modified the sentence, reducing it to seventeen (17) years, four (4) months, and one (1) day of reclusion temporal. The conviction was based on evidence proving his collaboration with the Japanese Kempei Tai during the Japanese occupation of the Philippines.
Background
The case arose from allegations that Teofilo Paar actively assisted the Japanese Military Police (Kempei Tai) in identifying, arresting, and interrogating individuals suspected of being part of the underground resistance movement. The prosecution pursued only four counts out of the original fifteen, focusing on Paar’s overt acts of treasonous collaboration with the enemy.
Criminal Law II

Sayo vs. Chief of Police of Manila

12th May 1948

ak914931
80 Phil., 859 , No. L-2128
Summary
This case questioned whether delivering a person arrested without a warrant to the City Fiscal of Manila qualifies as a "judicial authority" under Article 125 of the Revised Penal Code. The Supreme Court ruled that the term "judicial authority" refers only to courts or judges empowered to issue an arrest or commitment order. The continued detention of petitioners without proper judicial process was deemed illegal, and their release was ordered.
Background
Petitioners Melencio Sayo and Joaquin Mostero were arrested on April 2, 1948, for alleged robbery, based on a complaint by Bernardino Malinao. They were detained without a warrant and brought to the Office of the City Fiscal of Manila. When no proper court process was issued for their continued detention after six hours, they filed a petition for habeas corpus.
Criminal Law II

People vs. Prieto

29th January 1948

ak237843
80 Phil. 138 , No. L-399
Summary
The case involves Eduardo Prieto, who was prosecuted for treason on seven counts in the People's Court. After initially pleading not guilty to all counts, he later changed his plea to guilty on counts 1, 2, 3, and 7. The Supreme Court modified the death penalty to reclusion perpetua, finding him guilty of treason as charged in counts 1, 2, 3, and 7, with one aggravating circumstance offset by his plea of guilty.
Background
The case arose from actions committed during the Japanese occupation of the Philippines in 1944-1945. The accused, Eduardo Prieto, acted as an undercover agent for the Japanese Military Police, participating in various activities against suspected guerrillas and their supporters.
Criminal Law II

People vs. Agpangan

10th October 1947

ak427419
79 Phil. 334 , No. L-778
Summary
A treason case where the Supreme Court acquitted the defendant due to the prosecution's failure to satisfy the two-witness rule in proving treasonous overt acts, and due to compelling evidence that the defendant's actions were done under duress after the Japanese killed a guerrilla member in his house and threatened him with the same fate.
Background
The case arose during the Japanese occupation of the Philippines in World War II. The defendant was accused of being a member of pro-Japanese organizations (Ganap and Pampars) and performing duties that aided the Japanese forces against Filipino and American forces between December 1944 and January 1945 in Laguna Province.
Criminal Law II

People vs. Adriano

30th June 1947

ak298371
78 Phil. 561 , No. L-477
Summary
The Supreme Court reversed a treason conviction due to insufficient evidence under the two-witness rule, establishing that witnesses must testify to the same overt act rather than separate instances of similar conduct.
Background
During the Japanese occupation of the Philippines between January and April 1945, Apolinario Adriano was accused of treason for joining the Makapili organization and allegedly participating in various activities supporting Japanese forces against the United States and Philippine Commonwealth forces.
Criminal Law II

Laurel vs. Misa

30th January 1947

ak294241
77 Phil. 856 , G.R. No. 409
Summary
This case involves a petition for habeas corpus filed by Anastacio Laurel, who argued that a Filipino citizen who adhered to the enemy during the Japanese occupation could not be prosecuted for treason. Laurel contended that the sovereignty of the legitimate government and the correlative allegiance of Filipino citizens were suspended during the occupation, and that there was a change of sovereignty with the proclamation of the Philippine Republic. The Supreme Court denied the petition, holding that a citizen's absolute and permanent allegiance to their legitimate government is not abrogated by enemy occupation, and therefore, treason could be committed against the Philippine government during that period.
Background
The case arose in the aftermath of World War II, specifically following the Japanese occupation of the Philippines. During this period, some Filipino citizens were alleged to have collaborated with the Japanese forces. Anastacio Laurel was one such individual accused of treason for acts committed during the occupation.
Constitutional Law I Criminal Law II Statutory Construction

People vs. Lol-lo and Saraw

27th February 1922

ak656044
43 Phil. 19 , No. 17958
Summary
A landmark piracy case in the Philippines where two Moro pirates were convicted for attacking a Dutch vessel, committing robbery, rape, and attempted murder. The Supreme Court upheld jurisdiction over the crime despite it occurring in foreign waters, establishing that piracy is a crime against all nations that can be tried anywhere.
Background
The case arose from a horrific act of piracy in the Dutch East Indies where Moro pirates attacked Dutch subjects, committed robbery, rape, and attempted murder. The perpetrators later returned to the Philippines where they were arrested and tried, raising important questions about jurisdiction and the applicability of Spanish-era piracy laws.
Criminal Law II