People vs.

Mariano HOLDING:
1. Defendant asserts that he only exercised his authority to eject the deceased.
However, the court ruled that his violence was far in excess of such authority. Even
US v BROBST if the accused did not intend to kill, there can be no doubt that by striking Saldivar,
Related Provisions: he intended to do him some injury. One is not relieved from criminal liability for
At the time or the case: the natural consequences of one's illegal acts, merely because one does not
Penal Code intend to produce such consequences.
Art 1. Any person voluntarily committing a crime or misdemeanor shall incur 2. The deceased was in apparent good health; after receiving the blow immediately
criminal liability, even though the wrongful act committed be different from that thereafter, started up the short trail to his sister's house and he died as he reach
which he intended to commit. the door. "In the absence of evidence of any intervening cause, we think there can
Criminal Liability: How Incurred be no reasonable doubt that his death resulted from the blow."

SUMMARY: RULING:
Brobst and Mann are owners of a mine. Mann fired Saldivar, calling him a thief and Judgment of conviction by the trial court is affirmed.
was a disturbance and warned him to never come back. A few days later, Saldivar
came back to the mine with 3 others looking for employment. Upon seeing him, THE PEOPLE OF THE PHILIPPINES (PLAINTIFF-APPELLEE) VS. DOMINGO URAL
Brobst ordered him to leave to which Saldivar merely grinned. Brobst struck Saldivar (ACCUSED-APPELLANT) GR No.: L-30801
with a powerful blow with his closed fist just over the ribs. Saldivar left and died as
he reached the door to the house. The trial court held Brobst guilty of homicide. FACTS:
Brobst appealed. SC upheld judgement of conviction
ISSUES: - Alberio went to the municipal building and saw Ural, a policeman inside
1. WoN Brobst is guilty of homicide even if there was no intent to kill the jail where he was boxing prisoner Napola (who was imprisoned for being
2. WoN there was still doubt that the cause of death of was the single blow of drunk). When Napola fell to the ground he kicked him and poured some liquid on N
Brobst and then ignited N’s body.
FACTS:
- Dr. Luzonia Bakil who treated the victim, said that he sustained 2nd degree
1. Brobst and Mann engaged in work on a mine and gave employment to the
burns on the arms, neck, left side of the face and one half of the body including the
people of Masbate
back. She also testified that without any medical intervention, the burns would
2. Mann discharged Saldivar because he was a thief and warned him never to set have caused death
foot on the premises again
3. July 10, 1907 – Saldivar, with 3 others, went to the mine to look for work, was - Napola died on Aug 25 1966. Death certificate indicated burn as the cause
ordered to leave by Brobst and was then struck with a blow of death.
4. Saldivar staggered and went to the direction of his sister’s house 200 yards away
but died as he reached the door to the house. - During the trial, the prosecutors failed to present the detention prisoners
5. Brobst claims that he had a right to eject the deceased from the mining property who saw the burning of Napola as witnesses as well as the wife of the deceased
and that he merely pushed lightly, as proved by the body
- Nevertheless, Ural was convicted of murder, was sentenced to reclusion
with no external marks of Violence. He had not intended to kill Saldivar and did not
perpetua and was ordered to pay for costs
intend to do him any physical injury.
6. Dagadap and Yotiga, bystanders at the time, testified that the blow was indeed ISSUE: Whether the evidence of the prosecution was sufficient to prove his guilt
hard. beyond reasonable doubt.
7. The trial court held Brobst guilty of homicide and sentenced him to 6 years and 1
day of prision mayor Held: TC did not err in convicting Ural for murder.
8. Brobst appealed the decision
- Ural had his own version of the story. According to him he heard a scream
for help from Napola whose shirt was in flames when found by him, he removed
the shirt, but did not summon the doctor because he thought that the burns were US vs. Divino
not serious.
Facts: A girl named Alfonsa, about 13 years of age when the incident happened, was
o SC: this statement cannot prevail over the testimony of Alberio a servant for Feliciano Divino and his family. Her feet were the focus in this case
because it is said that Feliciano Divino burned her feet, in a very unorthodox and
o This statement does not prove that he was not the one who burned harmful way in a sense, by setting her feet on fire after applying petroleum to it and
Napola, at most this could only mean that he was alarmed by the consequences of tying her down to the floor. He argued in the court that when Alfonsa came to their
his evil act home, her body was full of scars and ulcers, and that the ulcer in her body was
cured, through his efforts.
- Ural assailed the credibility of Alberio as a witness, saying that he was not
listed as a prosecution witness and that he was convicted of murder in the past Issue: Whether Feliciano Divino can be acquitted because he argued that he acted
in good faith and did not mean any harm to the girl, except to help her get cured.
o Wouldn’t preclude him from being a credible witness.
Held: Medical arguments were brought in the light of the decision and that a doctor
o Since there was no police investigation (accused a police officer), the clearly identified that the scars on Alfonsa’s feet were indeed because of burns and
investigation that ensued was done by a special counsel of the fiscal’s office. A that the wounds became worse on account of Feliciano’s efforts to cure them.
possible explanation of alberio not being listed at first. Certainly it was found certain that the acts of the guilty person do not seem to have
been intended to cause an evil, but rather as a remedy. However, article 568 or the
o The statements of the witnesses for the defense were not inconsistent Penal Code clearly states that a person that undertakes medical assistance to
with that of Alberio’s. another person is liable for any injuries resulting from such treatment, and the fact
that he acted in good faith and according to the best of his ability does not relieve
Therefore, there is no reason to not believe in Alberio’s testimony.a
him from responsibility, although his ignorance may be considered as a mitigating
- The present case is covered by article 4 (par.1-result greater than what was circumstance.
intended).
US v. ANDRES VILLANUEVA
o Aggravating circumstance: art 14(1).
Facts:
o TC erred in not appreciating the Mitigating circumstance “that the
offender had no intention to commit so grave a wrong as that committed”  This case has come up on appeal from a judgment of the Court of First
Instance of Mindoro, by which Andres Villanueva was sentenced to two
No intent to kill but only to maltreat the drunk napola who might have months and fifteen days' arresto mayor, accessory imprisonment, to
been making a nuisance of himself indemnify the aggrieved party, Isidro Benter.
 Villanueva is charged "while quarreling with his opponent, Isidro Benter,
He realized the fearful consequence of his felonious act, he allowed Napola with having suddenly snatched the bolo which the latter was carrying at his
to secure medical treatment at the municipal dispensary belt and with it inflicting upon him a wound in the palm of the right hand
that incapacitated the aggrieved party from performing work for more
- Since the mitigating circumstance offset the aggravating circumstance, TC
than thirty days and which rendered the said principal member entirely
correctly imposed the penalty of reclusion perpetua which is the medium period of
useless."
the penalty for murder.
 Turns out that Villanueva was not Benter's opponent nor was there any
DECISION: TC decision AFFIRMED. quarrel between the two. Neither did Villanueva inflict wound upon
Benter. The latter injured himself by an accident arising out of his own act.
 Benter himself testified that while both of them were standing with their
arms folded it occurred to Villanueva to take hold of the bolo which
 complainant carried at his belt; that the complainant tried to retain it and
that in doing so he caught it by the blade and cut himself in the palm of the
right hand.
 Upon finding himself injured the complainant left the spot while Villanueva
remained there.
 act took place on the 5th of July, 1914, and the complaint was not filed
until the 10th of October, 1914
 Benter was able to testify that the wound delayed in healing for more than
forty days
 The trial was held on December 8, and then Benter showed a scar in the
right palm that ran from the base of tHe little finger to the first joint of the
index finger. The judge noted that the index finger was stiff and that the
man could not extend the ring finger.
 The principal charge of the accusation, that Villanueva inflicted upon
Benter the wound in question, is not proven in the slightest.
 The defense prayed for dismissal. The prosecution did not oppose it. But
the lower court denied the petition.

Issue: WON Villanueva is guilty of lesiones graves by reckless negligence

Held: No. The defendant did not wound Benter. It was the latter who, by his
own act in catching hold of the edge of the blade of the bolo, wounded himself.

The defendant did not wound, beat, or assault Benter; consequently he cannot
be guilty of the crime of inflicting serious physical injuries, not even by reckless
imprudence.

The defendant, in taking or attempting to take the bolo from its scabbard,
made not the slightest threat or any indication of striking with it. His action
appears to have been motived by mere curiosity. The accused was acquitted.