My Law School Story: Criminal Law I Case Digests
Preface
The case digests below are based on the topics we discussed in our class. As I mentioned in the previous article about how I digest cases, it is very important to read the syllabus or take note of the topic to be discussed to know where to focus. My style in digesting cases differs accordingly. Some of the cases below were digested 5 to 10 minutes before the oral recitation.
Topic: Proximate Cause
Title of the Case
People vs. Villacorta
G. R. No. 186412
September 7, 2011
Facts
Villacorta, the defendant, stabbed Cruz with a sharpened bamboo stick. Cruz was rushed and treated as an outpatient at the Tondo Medical Hospital. Days after, Cruz died due to tetanus.
Issue
Whether or not the proximate cause of the death of Cruz is the stab wound caused by Villacorta.
Ruling of The Court
No.
Proximate cause has been defined as "that cause, which, in a natural and continuous sequence, unbroken by any efficient intervening cause, produces the injury, and without which the result would not have occurred."
In this case, immediately after he was stabbed by Villacorta in the early morning of January 23, 2002, Cruz was rushed to and treated as an out-patient at the Tondo Medical Center. On February 14, 2002, Cruz was admitted to the San Lazaro Hospital for symptoms of severe tetanus infection, where he died the following day, on February 15, 2002. The prosecution did not present evidence of the emergency medical treatment Cruz received at the Tondo Medical Center, subsequent visits by Cruz to Tondo Medical Center or any other hospital for follow-up medical treatment of his stab wound, or Cruz’s activities between January 23 to February 14, 2002
WHEREFORE, the Decision dated July 30, 2008, of the Court of Appeals in CA-G.R. CR.-H.C. No. 02550, affirming the Decision dated September 22, 2006, of the Regional Trial Court, Branch 170, of Malabon, in Criminal Case No. 27039-MN, is REVERSED and SET ASIDE. A new judgment is entered finding Villacorta GUILTY beyond reasonable doubt of the crime of slight physical injuries, as defined and punished by Article 266 of the Revised Penal Code, and sentenced to suffer the penalty of thirty (30) days arresto menor. Considering that Villacorta has been incarcerated well beyond the period of the penalty herein imposed, the Director of the Bureau of Prisons is ordered to cause Villacorta’s immediate release, unless Villacorta is being lawfully held for another cause, and to inform this Court, within five (5) days from receipt of this Decision, of the compliance with such order. Villacorta is ordered to pay the heirs of the late Danilo Cruz moral damages for Five Thousand Pesos (₱5,000.00).
Topic: Revised Penal Code (RPC) Article 11, paragraph 4
VICKY C. TY v. PEOPLE
GR No. 149275
September 27, 2004
Facts:
l This case stemmed from the filing of seven (7) Information for violation of B.P. 22 against Ty before the RTC of Manila.
l prosecution shows that Ty's mother... was confined at the Manila Doctors' Hospital (hospital) from October 30, 1990, until June 4, 1992.
l the Statement of Account... shows the total liability of the mother in the amount of P657,182.40. Ty's sister, Judy Chua, was also confined at the hospital... incurring hospital bills in the amount of P418,410.55.
l the total hospital bills of the two patients amounted to P1,075,592.95. On June 5, 1992, Ty executed a promissory note wherein she assumed payment of the... obligation in installments.
l To assure payment of the obligation, she drew several postdated checks against Metrobank payable to the hospital. The seven (7) checks, each covering the amount of P30,000.00, were all deposited on their due... dates. But they were all dishonored by the drawee bank and returned unpaid to the hospital due to insufficiency of funds, with the "Account Closed" advice.
l demand... letters were not heeded, complainant filed the seven (7) Informations subject of the instant case.
l Ty claimed that she issued the checks because of "an uncontrollable fear of a greater injury." She averred that she was forced to issue the checks to obtain release for her mother whom the hospital inhumanely and harshly treated and would not discharge... unless the hospital bills are paid. She alleged that her mother was deprived of room facilities, such as the air-conditioning unit, refrigerator, and television set, and subject to inconveniences such as the cutting off of the telephone line, late delivery of... her mother's food, and refusal to change the latter's gown and bedsheets.
She also bewailed the hospital's suspending medical treatment of her mother.
that... the latter contemplated suicide if she would not be discharged from the hospital.
Issue
Whether or not the justifying circumstance is appreciated to warrant her exemption from criminal liability
Ruling:
NO. The Supreme Court finds the petition without merit and accordingly sustains Ty's conviction.
For this exempting circumstance to be invoked successfully, the following requisites under Article 11, paragraph 4 of the RPC must concur:
First. ...the evil sought to be avoided actually exists;
She also bewailed the hospital's suspending medical treatment of her mother.
According to the Court, a mere threat of a future injury is not enough. It should not be speculative, fanciful, or remote.
Second. ...the injury feared to be greater than that done to avoid it;
If the evil sought to be avoided is merely expected or anticipated or may happen in the future, this defense is not applicable.
and Third. There be no other practical and less harmful means of preventing it.
Ty could have taken advantage of... an available option to avoid committing a crime. By her own admission, she had the choice to give jewelry or other forms of security instead of postdated checks to secure her obligation.
Moreover, for the defense of the state of necessity to be availing, the greater injury feared should not have been brought about by the negligence or imprudence, more so, the willful inaction of the actor.
In this case, the issuance of the bounced checks... was brought about by Ty's own failure to pay her mother's hospital bills.
WHEREFORE, the instant Petition is DENIED and the assailed Decision of the Court of Appeals, dated 31 July 2001, finding petitioner Vicky C. Ty GUILTY of violating Batas Pambansa Bilang 22 is AFFIRMED with MODIFICATIONS. Petitioner Vicky C. Ty is ORDERED to pay a FINE equivalent to double the amount of each dishonored check subject of the seven cases at the bar with subsidiary imprisonment in case of insolvency by Article 39 of the Revised Penal Code. She is also ordered to pay the private complainant, Manila Doctors’ Hospital, the amount of Two Hundred Ten Thousand Pesos (₱210,000.00) representing the total amount of the dishonored checks. Costs against the petitioner.
To be updated...
