Criminal Law,  Legally Yours

Del Castillo Case Doctrines (Criminal Law – Revised Penal Code Book 1)

Del Castillo Case Doctrines

Summaries of case doctrines penned by Justice Del Castillo.

Criminal Law Revised Penal Code Book 1

Lamauig v. People
G.R. No. 166680, July 7, 2014The same act may give rise to two or more separate and distinct charges and innocence in one case does not necessarily prove innocence in the other charge.

People v. Agacer, et, al.
G.R. No. 177751, December 14, 2011

Conspiracy may be inferred from the acts which lead to a joint purpose and design, concerted action and community of interest. Proof of a previous agreement and decision to commit the crime is not essential but the fact that the malefactors acted in unison pursuant to the same objective suffices.

People v. Barcela y Medina
G.R. No. 179948, December 8, 2010

Proof of actual force or intimidation is not necessary to convict the accused of the crime of rape if the same is incestuous.

People v. Baron y Tangarocan
G.R. No. 185209, June 28, 2010

To avail of the exempting circumstance of irresistible force or uncontrollable fear of an equal or greater injury, the evidence must establish that:

1) the existence of uncontrollable fear;
2) that the fear be must real and imminent; and
3) that the fear of an inquiry is greater than or at least equal to that committed.

People v. Beduya
G.R. No. 175315, August 9, 2010

Abuse of superior strength is present whenever there is a notorious inequality of forces between the victim and the aggressor. The presence of two persons in attacking the victim does not per se establish that the crime was committed with abuse of strength.

People v. Biglete
G.R. No. 182920, June 13, 2012

To constitute treachery, the attack must be so swift and unexpected, affording the victim no opportunity to defend himself. On the other hand, the use of motor vehicle may be considered an aggravating circumstance when the motorcycle was used as a means to commit the crime and to facilitate escape.

People v. Bustamante, et. al.
G.R. No. 172357, Match 19, 2010

There is the aggravating circumstance of superior strength when the perpetrators of the crime are members of the PNP and such crime was done in the performance of their functions.

People v. Cabtalan
G.R. No. 175980, February 15, 2012

There is treachery when the victim was attacked in a dark place while the victim is urinating with his back facing the assailants. The essence of treachery is that the attack comes without a warning and in a swift, deliberate, and unexpected manner, affording the hapless, unarmed, and unsuspecting victim no chance to resist or escape.

People v. Campos and Acabo
G.R. No. 176061, July 4, 2011

There can be no self-defense in the absence of an unlawful aggression from the person injured or killed. There must be an actual, sudden and unexpected attack, or imminent danger thereof, not merely a threatening or intimidating attitude.

People v. Jalbonian
G.R. No. 180281, July 1, 2013

Treachery is present when the victim is stabbed on the back and the assailant swiftly ran away. Clearly, the execution of the killing left the victim with no opportunity to defend himself or to retaliate.

People v. Lalog, et. al.
G.R. No. 196753, April 21, 2014

To avail of self-defense as a justifying circumstance, it must be proved with certainty by satisfactory and convincing evidence which excludes any vestige of criminal aggression on the part of the person invoking it.

People v. Lucero
G.R. No. 179044, December 6, 2010

Treachery can exist even if the attack is frontal, as long as the attack is sudden and unexpected, giving the victim no opportunity to repel it or to defend himself.

People v. Mamaruncas, et. al.
G.R. No. 179497, January 5, 2012

Conspiracy is present when there is closeness and coordination as to unmistakably indicate a common purpose and design.

People v. Pojo
G.R. No. 183709, December 6, 2010

In order for qualifying circumstances to be considered in convicting the accused, they must be alleged in the information. However, even if not alleged, the same may still be considered in ascertaining the civil liability of the accused, if proven. Thus, such circumstances may justify the award of exemplary damages.

People v. Ramos
G.R. No. 190340, July 24, 2013

A plea of self-defense may be belied by the nature, number, and location of wounds inflicted on the victim as they are indicative of a determined effort to kill and not just to defend.

People v. Solano, Jr.
G.R. No. 199871, June 2, 2014

Circumstantial evidence is sufficient to convict an accused if:
1) there is more than one circumstance ;
2) the facts from which the inferences are derived are proven; and
3) the combination of all circumstances is such as to produce a conviction beyond reasonable doubt.

People v. Soria
G.R. No. 179031, February 24, 2014

The death of the accused pending appeal of his conviction extinguishes his criminal liability, as well as his civil liability ex delicto.

People v. Soriano y Narag
G.R. No. 216063, June 5, 2017

Treachery is present even if the victim was previously warned of the danger to his person if it was impossible for him to retaliate.

People v. SPO1 Alawig
G.R. No. 187731, September 18, 2013

In evident premeditation, a sufficient lapse of time between the determination and the actual execution of the crime allowing the accused time to reflect upon the consequences of his act is necessary.

People v. Sumilhig, et. al.
G.R. No. 178115, July 28, 2014

Treachery is evident when the suddenness and unexpectedness of the assault deprived the victims of an opportunity to resist it or offer any defense to their persons.

People v. Yanson
G.R. No. 179195, October 3, 2015

For treachery to be considered, two elements must concur:
1) the employment of means of execution that gives the person attacked no opportunity to defend themselves or retaliate; and
2) the means of execution were deliberately or consciously adopted.

Pinlac v. People
G.R. No. 197458, November 11, 2015

An accused may enjoy the benefits of the Indeterminate Sentence Law despite conviction under a special law.

Quidet v. People
G.R. No. 170289, April 8, 2010

Simultaneousness of the attack does not of itself demonstrate conspiracy, what is determinative is proof that the accused were animated by one and the same purpose.

Sauritan y Jara v. People of the Philippines
G.R. No. 172896, April 19, 2010

Criminal liability shall be incurred by any person committing a felony although the wrongful act done be different from that which he intended. He who is the cause is the cause of the evil caused.

Villarin and Latayada v. People
G.R. No. 175289, August 31, 2011

Lack of criminal intent is not a valid defense in an offense which is malum prohibitum.

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