For Mark

PEOPLE vs.
ILIGAN
191 SCRA 643
Case #: GR 75369
Date: 11.26.90
Ponente: J. Fernan
Parties:
People of the Philippines, plaintiff-appellee,
Fernando Iligan y Jamito, Edmundo Asis y Iligan and Juan Macandong (at large), defendants-appellants.
Nature of the Case:
Appeal to seek reversal of decision of Court of First Instance
Facts:
x Edmundo Asis, one of the defendants pushed
Quinones group which prompted one of Quinones companion to punch him. Upon seeing Asis fall, Iligan drew his bolo and hacked
Quinones companion but missed. Terrified, Quinones group ran pursued by Iligans group.
When they realized that they were no longer being followed, Quinones decided to go to his house.
x While walking towards Quinones house, the three accused suddenly emerged on the roadside and then Fernando Iligan hacked
Quinones with a bolo hitting him on the forehead and causing him to fall down.
x The death certificate issued indicates that Quinones, Jr. died of shock and massive cerebral hemorrhages due to vehicular
accident.
x The Court of first Instance of Camarines Norte convicted Fernando Iligan and Edmundo Asis for the crime of murder. The lower
court held that there were aggravating circumstances of treachery and evident premeditation on the part of Iligan while Asis was
held liable for conspiracy.
Issues:
1. WON Iligan has criminal liability/ WON he is liable for murder.
2. WON Edmund Asis has criminal liability for conspiracy
Decision:
1. Yes, Iligan has criminal liability because although the hacking of the victims head was not the direct cause of death it is the
proximate cause. However, the court held that the aggravating circumstances for treachery and premeditation were not present.
Thus, Iligan was only convicted of homicide and not murder.
2. No, Edmund Asis has no criminal liability.
Ratio:
x Art 4 of Rev. Penal Code. Criminal liability shall be incurred "by any person committing a felony (delito) although the wrongful act
done be different from that which he intended.
x Requisites of Art 4.
o that an intentional felony has been committed
o that the wrong done to the aggrieved party be the direct, natural and logical consequence of the felony committed by the
offender
x Requisites for evident premeditation
o the time when the accused determined to commit the crime
o an act manifestly indicating that the accused had clung to their determination to commit the crime
o the lapse of sufficient length of time between the determination and execution to allow him to reflect upon the consequences of his act
Analysis:
1. Iligan has criminal liability but not murder
x Intentional felony committed: hacking of the head
o The instrument used and the location of the wound showed that the intention is to kill and not merely to immobilize the
victim
x The hacking incident happened on the national highway. After the victim was hacked with a bolo by Iligan, he fell down and
then he was run over by a vehicle.Hacking of the head may not be the direct cause of death but it was the proximate cause
of death.
x Treachery not evident. Suddenness of attack does not by itself show treachery. Mode of attack should make it impossible or
hard for the victim to defend himself.
x Requisites for evident premeditation not met.
2. Asis has no criminal liability
x mere knowledge, acquiescence or approval of the act without cooperation or agreement to cooperate, is not enough to
constitute one a party to a conspiracy
x did not take any active part in the infliction of the wound on the head of Quiones, Jr
Definition:
Proximate legal:
"that acting first and producing the injury, either immediately or by setting other events in motion, all constituting a natural and
continuous chain of events, each having a close causal connection with its immediate predecessor, the final event in the chain
immediately effecting the injury as a natural and probable result of the cause which first acted, under such circumstances that
the person responsible for the first event should, as an ordinarily prudent and intelligent person, have reasonable ground to
expect at the moment of his act or default that an injury to some person might probably result therefrom."
PEOPLE vs. MANANQUIL
132 SCRA 198
Facts: Issues:
Defendant, wife of the victim, went to his post as a) W/N appellants extrajudicial confession was
security guard in the evening, poured gasoline over her voluntarily given
husband and threw a lighted match at him, afterwhich
the victim burned. He died at the hospital after four b) W/N the burns of victim caused pneumonia, which
days, and autopsy reported the cause of death to be caused the victims death
pneumonia, lobar bilateral, second degree burns
secondary. After being found guilty, defendant filed an
appeal, arguing that the court erred Held/Ratio:
a) in convicting her solely on the basis of the alleged

extrajudicial confession, b) in finding that pneumonia a) YES. An extrajudicial confession is generally
was a complication of the burns sustained by the regarded as conclusive proof of guilt when taken
victim, 3) in not finding her not to be the cause of death, without maltreatment or intimation, and presumed to
and 4) in not acquitting her at least on ground of
reasonable doubt.
be voluntary until otherwise proven. In this case, there

is not enough evidence to prove that it was not
voluntary. 1) Appellant understood Tagalog, which she
at first denied; 2) There are details in the confession
which the police couldnt possible have written if they
were not knowledgeable of the case; 3) It was given b) YES. RPC Art 4 is applicable here because there
shortly after the incident took place, which couldnt was intent and direct, natural and logical cause of the
have given her enough time to fabricate her statement; act to the death of the victim. She did not show any sign
while her contrasting testimony was given more than 5 of remorse on the suffering and death of her husband,
years after the incident. and her argument that the victims drinking of liquor
caused the pneumonia did not stand.
DECISION:
Affirmed, with modifications to increase monetary

punishment.
PEOPLE vs. MANANQUIL
132 SCRA 198
Case #: GR L-35574
Date: 09.28.84
Ponente: J. Cuevas
Parties:
People of the Philippines, plaintiff-appellee,
Valentina Mananquil, defendants-appellant.
She was tried, convicted and thereafter sentenced to

reclusion perpetua and ordered to indemnify the heirs
Facts:
of the victim in the amount of P12,000.
On 03.06.65, the defendant having in her possession She filed an appeal to the Court of Appeals, who
a bottle containing gasoline went to the NAWASA passed the case to the Supreme Court since the
area where her husband, Elias Day y Pablo, work. sentence was reclusion perpetua, contending that the
Without a warning she poured the contents of the trial court erred in convicting her based only on her
bottle to her husband and ignited the gasoline, extrajudicial confession, which she claims she only
causing her husband to suffer from burns and injuries
signed but did not understand (because it was written
(pneumonia, lobar bilateral with 2nd degree burn) in Tagalog) as the police promised that they will let
which subsequently caused his death four days after her go. She also contends the finding of the court that
the incident. pneumonia which is the actual cause of death of the
victim was a complication of the burns sustained by
the victim and that she was not acquitted on the x It has been 5 years since the incident when
ground of reasonable doubt. she took the stand which would enable her
to create her own story
She claimed that she only went to her husbands work x Her intent was made clear by the fact that she
to bring gasoline for his lighter but upon seeing her, was indifferent and unperturbed over the fate
the victim cursed her. She trembled and became of her husband she never attended the
dizzy that she didnt realized that she was already funeral nor did she come to see her husband
sprinkling gasoline to her husbands face. Then she once in the hospital
left her husband upon remembering that her grandson
is at home alone. 2.. Pneumonia caused by burns
x The fact that Elias was drinking alcohol was

not an efficient intervening cause for his
Issues: having pneumonia according to Dr. Reyes
1. WON Valentinas extrajudicial confession was
voluntarily given. x
2. WON the burns sustained by the victim contributed

to pneumonia which caused his death
Decision:
The court held that the extrajudicial confession would

be accepted by the court as evidence and that the
burns sustained by the victim contributed to the cause
of his cause of death.
Analysis:
1. Confession
x Extrajudicial confession can be regarded as

conclusive proof of guilt when taken without
maltreatment or intimidation and may serve
as basis for conviction; burden of proof for
the contrary rests with the person who gave
the confession The confession of Valentina
was taken shortly after the incident thus
she was not able to create lies which would
be favorable to her.
Ratio:

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PEOPLE vs.

191 SCRA 643

People of the Philippines, plaintiff-appellee,

Nature of the Case:

Appeal to seek reversal of decision of Court of First Instance

x Edmundo Asis, one of the defendants pushed

1. WON Iligan has criminal liability/ WON he is liable for murder.

2. WON Edmund Asis has criminal liability for conspiracy

o that an intentional felony has been committed

x Requisites for evident premeditation

o the time when the accused determined to commit the crime

1. Iligan has criminal liability but not murder

x Intentional felony committed: hacking of the head

x Requisites for evident premeditation not met.

2. Asis has no criminal liability

PEOPLE vs. MANANQUIL

132 SCRA 198

a) in convicting her solely on the basis of the alleged

be voluntary until otherwise proven. In this case, there

Affirmed, with modifications to increase monetary

132 SCRA 198

People of the Philippines, plaintiff-appellee,

Valentina Mananquil, defendants-appellant.

She was tried, convicted and thereafter sentenced to

x The fact that Elias was drinking alcohol was

2. WON the burns sustained by the victim contributed

The court held that the extrajudicial confession would

x Extrajudicial confession can be regarded as

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