Case Digests - Title 1
Case Digests - Title 1
ESTREMOS
Laurel v Misa Any favorable effect toward the Japanese that the accused might
TREASON have made was trivial, imperceptible and unintentional.
A petition for habeas corpus was filed by Anastacio Laurel. Intent of disloyalty is a vital ingredient in the crime of treason, which,
in the absence of admission, may be gathered from the nature and
He claims that a Filipino citizen who adhered to the enemy giving circumstances of each particular case.
the latter aid and comfort during the Japanese occupation cannot
be prosecuted for the crime of treason for the reasons (defenses): In this particular case, it was not evident that the intent of the
1. that the sovereignty of the legitimate government in the accused in providing the enemies with women was to help them
Philippines and, consequently, the correlative allegiance of overthrow the government.
Filipino citizen thereto were then suspended; and
2. that there was a change of sovereignty over these Islands Note: But the accused (Perez) may be punished for the rape of
upon the proclamation of the Philippine Republic. Ramo, Daohog, Lamay and Bonalos as principal by direct
participation. Without his cooperation in the manner above stated,
these rapes could not have been committed.
HELD:
Sexual and social relations with the Japanese did not directly and
materially tend to improve their war efforts or weaken the power of
the government.
Title I - 1
CRIMINAL LAW II CASE DIGESTS ON TITLE I BY: DOMINIC B. ESTREMOS
In 1903, a junta was organized and a conspiracy entered into by a Six vintas intercepted one of the two Dutch boats, carrying eleven
number of Filipinos in Hongkong, for the purpose of overthrowing men, women and children. The six vintas were manned by 24
the Government by force and arms and establishing in its stead a moros all armed.
government to be known as Republica Universal Democratica
Filipina At first, the Moros asked for food. But when they got on the Dutch
boat, they took for themselves all the cargo, attacked some of the
Primo Ruiz was recognized as the titular head of this conspiracy men, and brutally violated two of the women by methods too
and Artemio Ricarte as chief of the military forces to be organized in horrible to be described.
the Philippines in furtherance of the plans of the conspirators.
All of the persons on the boat, with the exception of the two young
Ricarte came to Manila from Hongkong; that after his arrival in women, were again placed on it and holes were made in it, with the
Manila, he held a number of meetings where it perfected the idea that it would submerge. After eleven days of hardship and
conspiracy hatched in Hongkong. privation, they were succored (saved).
The defendant Francisco Bautista took part in several of the Two of the marauders were Lol-lo, who also raped one of the
meetings whereat the plans of the conspirators were discussed and women, and Saraw.
perfected; and that one of these meetings, Bautista assured Ricarte
that the necessary preparation had been made and that he “held They later returned to their home in South Ubian, Tawi-Tawi, Sulu.
the people in readiness.” They were arrested there and were charged in the CFI of Sulu with
the crime of piracy.
Tomaz Puzon held several conferences whereat plans are made
for the coming insurrection. He was appointed Brigader-General of
the Signal Corps of the revolutionary forces by Jose Munoz. ISSUE: WON the Philippine courts have jurisdiction over the crime
of piracy alleged in this case.
He contended that he had accepted the appointment with no
intention of ever taking any further action. When Munoz offered him
the appointment, he did so in a “joking tone,” and that Puzon did not HELD:
know that Ricarte was in Manila organizing the conspiracy at that
time. It cannot be contended with any degree of force that the CFI of Sulu
was without jurisdiction on the case. Piracy is a crime, not against
Aniceto de Guzman accepted some bonds from one of the any particular state, but against all mankind.
conspirators for the purpose of raising funds for carrying out the
plans of the conspiracy. It may be punished in the competent tribunal of any country where
the offender may be found or into which he may be carried. Nor
does it matter that the crime was committed within the jurisdictional
ISSUE: WON the 3 accused are guilty of conspiracy. three-mile limit of a foreign state.
HELD: The crime of piracy was accompanied by (1) rape, and (2) the
abandonment of persons without means of saving themselves.
Yes. For Bautista and Puzon, they are guilty of conspiraacy.
Lol-lo, who raped on of the women, was sentenced to death, there
Bautista was fully aware of the purposes of the meetings he being an aggravating circumstance of cruelty, abuse of superior
participated in, and even gave an assurance to the chief of police strength, and ignominy, without any mitigating circumstance.
that he is making the necessary preparations.
Title I - 2
CRIMINAL LAW II CASE DIGESTS ON TITLE I BY: DOMINIC B. ESTREMOS
People v Rodriguez
PIRACY When the boat came close to them, Kiram threw a rope to the other
pumpboat which towed de Guzman’s pumpboat towards Mataja
Jaime Rodriguez, et. al. were charged of the crime of piracy. Island
Within the territorial waters of Tawi-Tawi, Rodriguez and three On the way to Mataja Island, de Guzman and his companions were
others, being crew members of M/V Noria 767, conspiring and divested of their money and their goods by Kiram,. Thereafter ,
confederating together and mutually helping one another, armed Kiram and his companions ordered the group of de Guzman to
with bladed weapons and high caliber firearms. undress. Taking fancy on the pants of de Guzman, Kiram put it on.
With intent to gain and by means of violence and intimidation upon With everybody undressed, Kiram said “It was good to kill all of
persons, did then and there, willfully and unlawfully, take, steal and you.” After that remark, Siyoh hacked Danilo Hiolen, while Kiram
carry away equipment and other personal belongings of the crew hacked Rodolfo de Castro.
and passengers.
Antonio de Guzman jumped into the water. As he was swimming
By the reason of the said piracy, accused stab and shot the away from the pumpboat, the two companions of Kiram fired at him,
persons, which produces the death of several persons and inflicted injuring his back. But he was able to reach a mangrove where he
several physical injuries to others. stayed till nightfall.
Three of the accused pleaded guilty and sentenced to suffer the When he left the mangrove, he saw the dead bodies of his friends.
extreme penalty of death.
He was picked up by a fishing boat and brought to the Philippine
Peter Ponce, however, entered the plea of not guilty. Army Station where he received first aid treatment. Later, he was
brought to a hospital.
HELD:
An order of arrest was then issued against all of the accused but
Under the Anti-Piracy Law (PD 532), it is clear that the penalty only Siyoh and Kiram were apprehended. After trial, the accused
imposable upon persons found guilty of the crime of piracy where were convicted of the crime of Qualified Piracy
rape, murder or homicide is committed is mandatory death penalty.
HELD:
Relative to the appeal of Ponce, which the Court declare to be
without merit, evidence shows that his participation in the They were guilty beyond reasonable doubt of qualified piracy with
commission of the offense was positively testified to by the master triple murder and frustrated homicide.
of the vessel, and a passenger. Another witness also pointed to
have seen Ponce armed with a M-14 rifle. The number of persons killed on the occasion or piracy is not
material. PD 532 (Anti-Piracy and Anti-Highway Robbery Law of
Thus, there can be no question that he was in conspiracy with the 1974) considers qualified piracy, i.e., rape, murder, or homicide, is
three other defendants. committed as a result or on the occasion of piracy, as a special
complex crime punishable by death, regardless of the number of
victims.
People v Siyoh Appellants’ claim that they were not the assailants but also the
PIRACY victims is baseless as viewed in the proven conspiracy among the
accused. The conspiracy was established through the testimony of
Julaide Siyoh and Omarkayam Kiram, together with Namli Indanan the lone witness and survivor, de Guzman, and these facts:
and Andaw Jamahali, were accused of qualified piracy with triple Both accused were talking to two armed strange-looking
murder and frustrated murder men
Du Guzman recognized their captors to be the same two
On 1979, Antonio de Guzman and his friends, who were also armed strangers to whom the two accused talked
travelling merchants like him, were on their way to Pilas Island, The two accused, without order from the two armed
Basilan to sell goods. strangers, transferred the unsold goods to the captor’s
banca
After selling goods in Pilas, they went to the house of accused De Guzman and companions were divested of their
Kiram at Pilas. The following day, the group together with Kiram and jewelries and cash and undress while the two accused
Siyoh started selling goods. remained unharmed and unmolested
On July 14, 1979, they were heading back to Pilas from Baluk-Baluk
through riding a pumpboat where Siyoh positioned himself at the
front while Kiram operated the engine.
There were two persons on the other pumpboat who were armed
with armalites. De Guzman recognized them to be the same
persons he saw Kiram conversing with.
Title I - 3