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Padillo vs. People

9th October 2024

ak536847
G.R. No. 271012
Primary Holding
The Supreme Court acquitted Roel Gementiza Padillo because the prosecution failed to establish the validity of the search warrant's issuance and implementation, violating his constitutional rights, and failed to prove the integrity of the chain of custody of the seized items beyond a reasonable doubt.
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
Primary Holding
When the elements of statutory rape (victim below the statutory age) concur with special qualifying aggravating circumstances under Article 266-B of the Revised Penal Code (such as minority and relationship, victim below 7 years old, or offender's knowledge of victim's mental disability), the proper designation of the crime is "Qualified Rape of a Minor," not "qualified statutory rape"; the special qualifying circumstance absorbs the inherent circumstance of the victim's age, elevating the crime to qualified rape.
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
Primary Holding
The presumption of regularity in the performance of police duties cannot overcome the stronger presumption of innocence. The prosecution failed to establish guilt beyond reasonable doubt due to serious lapses in the chain of custody and the failure to properly prove the identities and credentials of mandatory insulating witnesses during the inventory of seized drugs. Accused-appellants are acquitted.
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
Primary Holding
The conviction of Mario Nisperos y Padilla for violation of Section 5, Article II of R.A. No. 9165 is reversed and set aside due to the prosecution's failure to prove an unbroken chain of custody, specifically regarding the presence of mandatory witnesses at the place of apprehension for the immediate inventory of seized drugs, leading to reasonable doubt.
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
Primary Holding
For the crime of rape by sexual intercourse through penile penetration to be consummated, the penis must penetrate the cleft of the labia majora (also known as the vulval or pudendal cleft), even in the slightest degree; mere touching or grazing of the external surface (mons pubis or fleshy part of the labia majora) without penetrating the cleft only constitutes attempted rape or acts of lasciviousness, depending on intent.
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
Primary Holding
The Court voided parts of Section 4 (the qualifiers "intent to intimidate" and "create risk to public safety") and Sections 12 (inciting to commit terrorism), 25(e) (automatic adoption of UN-designated terrorists), and 29 (detention without warrant for 24 days). Other provisions survived constitutional scrutiny.
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

Cadajas vs. People

16th November 2021

ak683274
915 Phil. 220 , G.R. No. 247348
Primary Holding
Inducing a minor, through persuasion via a computer system like Facebook Messenger, to create and send photos exhibiting their private parts constitutes the crime of child pornography under Section 4(c)(2) of R.A. No. 10175 in relation to Sections 4(a), 3(b), and (c)(5) of R.A. No. 9775; the crime is mala in se, requiring criminal intent (specifically, the intent to induce the prohibited act), which was proven in this case.
Background
The case arose from a romantic relationship between the petitioner (Christian Cadajas, 24 years old) and the victim (AAA, 14 years old), which started after AAA initiated contact. The relationship was discovered by AAA's mother (BBB) who disapproved due to AAA's minority. BBB later found messages on Facebook Messenger where petitioner was inducing AAA to send explicit photos, leading to the filing of criminal charges.
Criminal Law II
Searches and Seizures

Ridao vs. Handmade Credit and Loans, Inc.

3rd February 2021

ak229915
895 Phil. 554 , G.R. No. 236920
Primary Holding
Once a debtor introduces evidence of payment, the burden of going forward with the evidence shifts to the creditor, who then has the duty to produce evidence to show non-payment; material alterations on a promissory note made without the assent of the other contracting party render the instrument void and unenforceable by the party causing the alteration.
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
Primary Holding
The Supreme Court affirmed the Court of Appeals' decision, which upheld the Regional Trial Court's conviction of Joey Meneses y Cano for illegal sale of dangerous drugs, finding him guilty beyond reasonable doubt of violating Section 5, Article II of R.A. No. 9165.
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. Sapla

16th June 2020

ak889679
874 Phil. 240 , G.R. No. 244045
Primary Holding
Exclusive reliance on an unverified tip relayed by an anonymous informant is insufficient to engender probable cause that warrants an intrusive warrantless search and seizure; law enforcers must rely on their personal knowledge based on overt acts personally observed or other reliable circumstances, beyond the tip itself, to justify such a search.
Background
The case arises amidst the State's campaign against illegal drugs, juxtaposed with the fundamental constitutional right of individuals against unreasonable searches and seizures, emphasizing that the fight against drugs cannot be pursued by sacrificing constitutionally protected rights.
Criminal Law II
Searches and Seizures

People vs. Guillermo

27th November 2019

ak963268
926 SCRA 144 , 866 Phil. 690 , G.R. No. 229515
Primary Holding
The Supreme Court held that the prosecution failed to prove the guilt of Nida and Desiree Guillermo beyond reasonable doubt for the crime of illegal sale of dangerous drugs, primarily due to inconsistencies and irregularities in the conduct of the buy-bust operation and the chain of custody of the seized evidence.
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
Primary Holding
When sexual assault under Article 266-A(2) of the RPC (e.g., insertion of a finger into the vagina) is committed against a child victim under twelve (12) years old, the proper nomenclature is "Sexual Assault under paragraph 2, Article 266-A of the RPC in relation to Section 5(b) of R.A. No. 7610," and the imposable penalty is *reclusion temporal* in its medium period as provided in the second proviso of Section 5(b) of R.A. No. 7610, not the lower penalty of *prision mayor* under Article 266-B of the RPC, because R.A. No. 7610 provides stronger deterrence and special protection for child victims.
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
Primary Holding
The Supreme Court held that Lina Achieng Noah is guilty beyond reasonable doubt of illegally transporting dangerous drugs, affirming her conviction and life imprisonment sentence, as the prosecution successfully established an unbroken chain of custody for the seized shabu and proved all elements of the crime.
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
Primary Holding
The warrantless arrest and seizure of marijuana from Jimboy Suico were valid as incidental to a lawful arrest based on probable cause. The prosecution successfully established an unbroken chain of custody of the seized drugs, thus proving the corpus delicti and the appellant's guilt for illegal transportation of dangerous drugs under RA 9165.
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
Primary Holding
The conviction of Romy Lim y Miranda is reversed and set aside; he is acquitted due to the prosecution's failure to prove compliance with the mandatory requirements of Section 21 of R.A. 9165 concerning the chain of custody of the seized dangerous drugs, specifically the absence of required insulating witnesses during inventory and the lack of justifiable grounds for such non-compliance, thereby failing to establish the identity and integrity of the corpus delicti beyond reasonable doubt.
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
Primary Holding
The Supreme Court acquitted Basher Tomawis, holding that the prosecution failed to establish an unbroken chain of custody and did not comply with the mandatory requirements of Section 21 of RA 9165, thus failing to prove his guilt beyond reasonable doubt for the crime of illegal drug sale.
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
Primary Holding
The Supreme Court held that the Regional Trial Court properly took cognizance of the kidnapping case against SSgt. Osorio, and his detention was by virtue of a valid judicial process. The remedy of habeas corpus was deemed inappropriate as the restraint had become legal.
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
Primary Holding
A conviction for rape based solely on the testimony of the victim requires that such testimony be credible, natural, convincing, consistent with human nature and the normal course of things, and sufficient to establish guilt beyond reasonable doubt; lingering doubts arising from material inconsistencies, testimonial improbabilities, and inconclusive medico-legal findings warrant an acquittal.
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
Primary Holding
The Petition for Certiorari and Prohibition is dismissed for lack of merit due to prematurity, violation of the hierarchy of courts and the rule against forum shopping, and for failure to demonstrate grave abuse of discretion by the respondent judge. The Regional Trial Court of Muntinlupa City, Branch 204 has jurisdiction over Criminal Case No. 17-165.
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
Primary Holding
The waiver of Article 125 of the Revised Penal Code must coincide with the prescribed period for preliminary investigation. Detention beyond this period violates the accused's constitutional right to liberty. Detainees must be released if preliminary investigations exceed statutory timelines or if their cases are dismissed (even pending review), unless lawfully held for other causes.
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

Gamaro vs. People

27th February 2017

ak713753
806 Phil. 483 , G.R. No. 211917
Primary Holding
The actual recital of facts in the information, not the caption or the specific provision of law cited, determines the nature and cause of the accusation against an accused; thus, an accused can be convicted of a crime adequately described by the facts in the information, even if it's different from the specific paragraph of the statute initially designated, provided the accused is not deprived of the right to be informed of the charge.
Background
The case originated from a business venture in 2002 where Joan Fructoza E. Fineza (private complainant) would provide jewelry to petitioner Norma C. Gamaro and her daughters, petitioner Josephine G. Umali and accused Rowena Gamaro, for them to sell. The agreement involved Fineza purchasing foreclosed jewelry identified by Umali (a pawnshop manager), Norma Gamaro selling them, and profits being split. Checks were issued as security for the jewelry.
Criminal Law II
Estafa

San Diego vs. CA

8th April 2015

ak478899
757 Phil. 599 , G.R. No. 176114
Primary Holding
An employee who, by virtue of their position (e.g., accountant, cashier, teller), has access to and physical possession of company funds but does not have juridical possession over them, commits qualified theft, not estafa, if they take and appropriate such funds with grave abuse of confidence and intent to gain.
Background
Petitioner Grace San Diego was employed as an accountant for Obando Fisherman's Multi-Purpose Cooperative, Inc. (OFMPCI) from January 1993 to March 11, 1997. Her responsibilities included accounting for all business transactions, performing cashier and teller functions, granting loans, check discounting, recording bank transactions, and handling pre-signed blank checks. She also temporarily acted as cashier and teller on separate occasions, giving her complete access to cash vaults and cooperative documents.
Criminal Law II
Qualified Theft

Benabaye vs. People

25th February 2015

ak922866
755 Phil. 145 , G.R. No. 203466
Primary Holding
An employee who receives money or property on behalf of an employer acquires only material or physical possession, not juridical possession; thus, the misappropriation or conversion of such money or property by the employee constitutes theft, not Estafa under Article 315, paragraph 1(b) of the Revised Penal Code.
Background
The case arose from an internal audit conducted by Siam Bank Inc., Iligan City Branch, which uncovered alleged fraud and irregularities in its loan transactions. Specifically, the audit revealed non-remittance of loan payments collected by its employees, including petitioner Cherry Ann Benabaye, who was a Loans Bookkeeper.
Criminal Law II
Theft

People vs. Jumawan

21st April 2014

ak373008
722 SCRA 108 , 733 Phil. 102 , G.R. No. 187495
Primary Holding
R.A. No. 8353, the Anti-Rape Law of 1997, unequivocally criminalizes marital rape, and the archaic doctrine of irrevocable implied consent to sexual intercourse within marriage is rejected; therefore, a husband can be convicted of raping his wife if the act is committed through force, threat, or intimidation, just like any other perpetrator, without requiring different elements of the crime or standards of proof.
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
Primary Holding
An act of laying hands on a child constitutes the crime of child abuse under Section 10(a) of Republic Act No. 7610 only if the prosecution proves beyond reasonable doubt that the accused specifically intended to debase, degrade, or demean the intrinsic worth and dignity of the child as a human being; otherwise, the act is punishable under the Revised Penal Code for physical injuries.
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
Primary Holding
The Supreme Court affirmed that police officers can be held liable for kidnapping when they act in their private capacity rather than in furtherance of official functions, upholding the conviction of PO1 Trestiza and his co-accused for kidnapping for ransom.
Criminal Law II

Soriano vs. People

1st February 2010

ak193031
625 Phil. 33 , G.R. No. 162336
Primary Holding
A bank officer violates the DOSRI law (Section 83 of RA 337) when he acquires bank funds for his personal benefit, even if such acquisition was facilitated by a fraudulent loan application using a third party's name; such fraudulent acquisition does not negate the "indirect borrowing" and can concurrently constitute the crime of estafa through falsification of commercial documents, as the officer holds the funds in a fiduciary capacity and misappropriates them.
Background
The Office of Special Investigation (OSI) of the Bangko Sentral ng Pilipinas (BSP) transmitted a letter with five affidavits to the Department of Justice (DOJ), alleging that Hilario P. Soriano, then president of the Rural Bank of San Miguel (Bulacan), Inc. (RBSM), orchestrated a fraudulent P8 million loan. The loan appeared in the name of spouses Enrico and Amalia Carlos, who denied applying for or receiving it. It was alleged that Soriano ordered, facilitated, and received the loan proceeds without board authorization or proper reporting, using an unsuspecting depositor's name.
Criminal Law II
Estafa

Jacinto vs. People

13th July 2009

ak482641
610 Phil. 100 , G.R. No. 162540
Primary Holding
The taking of a worthless check, even with intent to gain and grave abuse of confidence, constitutes an impossible crime under Article 4, paragraph 2, in relation to Article 59 of the Revised Penal Code, because the inherent lack of value in the check at the time of taking makes the consummation of theft factually impossible.
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

Laurel vs. Judge Abrogar

13th January 2009

ak193690
596 Phil. 45 , G.R. No. 155076
Primary Holding
The business of providing telecommunication and the telephone service itself are personal properties capable of appropriation and can be the subject of theft under Article 308 of the Revised Penal Code; the act of International Simple Resale (ISR), which involves unauthorized routing of international calls using a telecommunication company's facilities, constitutes unlawful taking (subtraction) of such business and service.
Background
The case arose from allegations that the petitioner, Luis Marcos P. Laurel, along with others, engaged in International Simple Resale (ISR). ISR is a method of routing and completing international long distance calls using a telecommunication company's lines, cables, antennae, and/or air wave frequency, connecting directly to local or domestic exchange facilities, thereby bypassing the official international gateway of the telecommunication company and depriving it of revenue.
Criminal Law II

Soria vs. Desierto

31st January 2005

ak603974
450 SCRA 339 , 490 Phil. 749 , G.R. Nos. 153524-25
Primary Holding
The Supreme Court upheld the time-honored practice of non-interference in preliminary investigations conducted by prosecutory bodies absent grave abuse of discretion, affirming that Sundays, holidays, and election days are excluded in computing the periods prescribed in Article 125 of the Revised Penal Code.
Criminal Law II

People vs. Comadre

8th June 2004

ak679022
431 SCRA 366 , 475 PHIL. 293 , G.R. No. 153559
Primary Holding
A single act, such as detonating a hand grenade, that results in death (Murder) and injuries (Attempted Murder) constitutes a complex crime under Article 48 of the RPC, punishable with the penalty for the most serious crime (Murder) applied in its maximum period; when both treachery and explosion attend the killing, explosion qualifies the crime to Murder if it was the principal means employed, while treachery is considered a generic aggravating circumstance. Conspiracy must be proven by positive acts of cooperation beyond mere presence or relationship, and absent such proof, co-accused cannot be held liable.
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
Primary Holding
The Supreme Court held that routine airport security procedures constitute a valid exception to the constitutional protection against warrantless searches and seizures. Persons may lose this protection due to reduced privacy expectations associated with air travel. When these procedures reveal contraband, and the accused is caught in flagrante delicto, both the warrantless search and subsequent arrest are valid. However, in imposing penalties for drug possession, courts must apply the lesser of two indivisible penalties when there are no aggravating or mitigating circumstances.
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
Primary Holding
The crime of frustrated rape does not exist in Philippine jurisprudence; any penetration of the female sex organ by the male organ, however slight, including mere entry into the labia or lips of the female organ ("mere touching of the external genitalia"), constitutes consummated rape.
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
Primary Holding
The Court held that when a complex crime has been charged in an information and the evidence fails to support the charge on one of the component offenses, the defendant can still be separately convicted of the other offense when properly established.
Criminal Law II

People vs. Catantan

5th September 1997

ak898009
278 SCRA 761 , 344 Phil. 315 , G.R. No. 118075
Primary Holding
The Supreme Court held that the acts of the accused constituted piracy under PD No. 532 and not merely grave coercion under Article 286 of the Revised Penal Code, as the seizure of the vessel through force and intimidation was established.
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
Primary Holding
Article 247 of the Revised Penal Code, which imposes the penalty of *destierro* on a legally married person who kills their spouse or the spouse's paramour immediately after surprising them in the act of sexual intercourse, does not define a crime but grants a special privilege or benefit, negating conviction for homicide or murder; consequently, the act cannot be qualified by circumstances like treachery, nor can it form part of a complex crime.
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
Primary Holding
The Supreme Court found Alvero guilty of treason and affirmed the sentence of reclusion perpetua but increased the fine from ₱10,000 to ₱20,000.
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
Primary Holding
The Supreme Court upheld Paar’s conviction for treason, finding that his actions demonstrated adherence to the enemy. However, due to the lack of evidence proving that his actions led to the execution of individuals, the penalty was reduced from reclusion perpetua to a lesser term of imprisonment.
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
Primary Holding
The term "judicial authority" in Article 125 of the Revised Penal Code (RPC) refers exclusively to judges or courts, not to a city fiscal. Detaining an individual beyond the prescribed period, without delivering them to a proper judicial authority, is unconstitutional and illegal.
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
Primary Holding
The Supreme Court held that when murder or physical injuries are charged as overt acts of treason, they cannot be regarded separately under their general denomination. The brutality of killing or physical injuries may be considered an aggravating circumstance but not as a separate crime.
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
Primary Holding
The Supreme Court reversed the lower court's decision and acquitted the appellant, finding that the prosecution failed to prove beyond reasonable doubt the alleged treasonous acts under the two-witness rule requirement, and that evidence suggested the appellant acted under duress.
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
Primary Holding
The Supreme Court held that membership in Makapili, while constituting an overt act of treason, must be proven by two witnesses testifying to the same specific instance, not different occasions of membership.
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
Primary Holding
A Filipino citizen's absolute and permanent allegiance to the legitimate government of the Philippines is not suspended or abrogated by enemy occupation, and consequently, such a citizen can be prosecuted for treason under Article 114 of the Revised Penal Code for acts of adherence and giving aid and comfort to the enemy committed during said occupation.
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
Primary Holding
The Court held that piracy is a crime against all mankind (hostes humani generis) that can be punished by any country regardless of where it was committed, and that the Spanish Penal Code provisions on piracy remained valid law in the Philippines after the American occupation.
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