People v.

Angus
626SCRA 503
Facts:
On or about the 10th day of January, 2002, at about 10:00 am, POrferio Angus, a member
of the Armed Forces of the Philippines, , with intent to kill, did then and there, willfully, unlawfully,
and feloniously attack, assault, choked and strangled the neck of his legitimate wife Betty Angus,
thereby causing her instantaneous death. Porferio argues that nobody really saw who killed the
victim or when and how she was killed. He asserts that the prosecution witnesses merely testified
to have last seen Betty alive on the night of January 9, 2002. The RTC found him guilty of parricide
. Hence, this petition.
Issue: Won Angus is entitled to presumption of innocence.
Held:
Yes. The Constitution mandates that an accused shall be presumed innocent until the
contrary is proven beyond reasonable doubt. The burden lies on the prosecution to overcome such
presumption of innocence by presenting the quantum of evidence required. In so doing, the
prosecution must rest on the strength of its own evidence and must not rely on the weakness of the
defense. And if the prosecution fails to meet its burden of proof, the defense may logically not even
present evidence on its own behalf. In such cases the presumption prevails and the accused
should necessarily be acquitted.

Zafra v. People
671 SCRA 396
Facts:
The prosecution charged Zafra and Marcelino with violation of Section 11, Article II of RA
No. 9165[3] before the RTC of Bulacan. The accused, without authority of law have in their
possession and control dangerous drug consisting of two (2) heat-sealed transparent plastic sachet
of methylamphetamine hydrochloride (shabu) weighing 0.061 gram, in conspiracy with one another.
The RTC, Branch 76, Malolos, Bulacan, in a decision dated 11 June 2008, convicted Zafra and
Marcelino for the crime of possession of shabu. Hence, this petition alleging that the chain of
custody was not followed.

Issue: Whether or not Zafra and Marcelino were entitled to the presumption of innocence.
Held:
Yes. In our constitutional system, basic and elementary is the presupposition that the
burden of proving the guilt of an accused lies on the prosecution which must rely on the strength of
its own evidence and not on the weakness of the defense. The rule is invariable whatever may be
the reputation of the accused, for the law presumes his innocence unless and until the contrary is
shown.In dubio pro reo. When moral certainty as to culpability hangs in the balance, acquittal on
reasonable doubt inevitably becomes a matter of right.

People v. Estibal
743 SCRA 215
Anecito Estibal raped her 13 year old daughter. The wife of the accused and mother the
victim, they disclaimed any further interest to pursue the case for they have has given Anacito. The
RTC convicted Anacito for rape. On appeal, the CA upheld the decision of the RTC. Anacito
alleged due to the absence of the private victims testimony, the prosecution failed to establish the
circumstances proving beyond reasonable doubt that he raped his daughter, thus it cannot create the
hearsay exception of res gestae and that the medical findings do not prove that he had carnal
knowledge over her daughter. Thus, he is entitled to the right to e presumed innocent. Hence, this
petition.
Issue: Whether or not Anecito was entitled to the presumption of innocence.

Held:
Yes. An accused has in his favor the presumption of innocence which the Bill of Rights
guarantees. Unless his guilt is shown beyond reasonable doubt, he must be acquitted. The burden
of proof is on the prosecution, and unless it discharges that burden the accused need not even
offer evidence in his behalf, and he would be entitled to an acquittal. The constitutional
presumption of innocence demands no less, even as it also demands no less than a moral
certainty of his guilt. Wherefore, Anecito Estibal is acquitted.

People v. Chavez
735 SCRA 728

Facts:
Mark Jason Chavez (Chavez) was charged with the crime of robbery with homicide.That on
or about October 28, 2006, in the City of Manila,the said accused, did then and there wilfully,
unlawfully and feloniously, with intent of gain and means of force, violence and intimidation upon
the person of Elmer Duque by then and there, with intent to kill, stabbing the latter repeatedly with
a kitchen knife, thereby inflicting upon him mortal stab wounds which were the direct and
immediate cause of his death thereafter, and on the said occasion or by reason thereof, accused
took, robbed and carried away the following:1 Unit Nokia Cellphone, 1Unit Motorola Cellphone, 6
pcs. Ladies Ring, 2pcs. Necklace, 1 pc. Bracelet. The trial court acquitted Chavez. On appeal, CA
affirmed the RTC.

Issue : Whether or not Chaves is entitled to the right to be heard and to counsel even if he
voluntarily surrender.
Held:
Yes, even those who voluntarily surrendered before a police officer must be apprised of
their Miranda rights. For one, the same pressures of a custodial setting exist in this scenario.
Chavez is also being questioned by an investigating officer in a police station. As an additional
pressure, he may have been compelled to surrender by his mother who accompanied him to the
police station. The Supreme Court finds that the circumstantial evidence sufficiently proves beyond
reasonable doubt that Chavez is guilty of the crime of homicide, and not the special complex crime
of robbery with homicide.

People v. Gumimba
517 SCRA 25
Facts:
Rogelio Gumimba and co-accused Ronie Abapo were charged before the RTC, with the
crime of rape with homicide of an eight (8)-year old child. Gumimba repeated his narration and
confessed to the barangay captain that he had raped and killed the victim, and that he was alone
when he committed the crime. On the basis of appellants plea of guilty, the RTC found him guilty
beyond reasonable doubt of the crime as charged. Hence, this automatic review for Gumimba was
sentenced to death penalty.

Issue: whether or not the accused were denied the right to be heard and to counsel.
Held:
Yes. RTC did not strictly observe the requirements under Section 3, Rule 116 above. A mere
warning that the accused faces the supreme penalty of death is insufficient. Such procedure falls
short of the exacting guidelines in the conduct of a searching inquiry, as follows:
(1) Ascertain from the accused himself (a) how he was brought into the custody of the law; (b)
whether he had the assistance of a competent counsel during the custodial and preliminary
investigations; and (c) under what conditions he was detained and interrogated during the
investigations. This is intended to rule out the possibility that the accused has been coerced or
placed under a state of duress either by actual threats of physical harm.

Salvador v.Limsiaco, Jr.

551 SCRA 373
Fact:
Julianito M. Salvador filed an administrative complaint for obstruction of justice, undue delay in
rendering a decision and gross inefficiency against Judge Manuel Q. Limsiaco, Jr. Salvador filed an
ejectment case in the MCTC in Negros Occidental. The case was heard but the parties failed to amicably
settle the case, respondent judge required them to submit their respective position papers. Complainant
moved for the early resolution of the case but the defendants opposed it. Respondent judge did not act on the
motion. Instead, he again required the complainant to submit a copy of his position paper respondent judge
finally rendered a decision dismissing the ejectment case for lack of cause of action.

Issue: Whether or not

Judge Manuel Q. Limsiaco, Jr. is guilty of undue delay in rendering

a decision
Held:
Yes. A judges foremost consideration is the administration of justice. Thus, he should follow the
time limit set for deciding cases. The Constitution mandates that all cases or matters filed before all lower
courts shall be decided or resolved within 90 days from the time the case is submitted for decision. Failure to
comply within the mandated period constitutes a serious violation of the constitutional right of the parties to
a speedy disposition of their cases It also undermines the peoples faith and confidence in the judiciary,
lowers its standards and brings it to disrepute.

WILLIAM CO vs. NEW PROSPERITY PLASTIC PRODUCTS

727 SCRA 503A

Facts:
New Prosperity Plastic Products, represented by Elizabeth Uy, filed 2 criminal case against Co
for violation of BP 22. The cases were provisionally dismissed. A Motion to Revive the Criminal Cases
was granted. Co opposed the revival by filing TRO but it was dismissed. The Supreme Court (SC)
dismissed the petition, there being no motion for reconsideration filed, the dismissal became final and
executory .Before the MeTC Branch 50 where 2 Criminal were re-raffled after the inhibition of Judge
Ortiz, Co filed a "Motion for Permanent Dismissal". Uy opposed the motion, contending that the motion
raised the same issues already resolved with finality by the SC however it was denied. The RTC set
aside the decision of MeTC. Co appeal to CA but it was dismissed. Hence, this petition.
Issue: (HINDI CAPSLACK CARLOTTE) WHETHER OR NOT THE DISMISSAL OF THE CRIMINAL
CASES AGAINST Co ONTHE GROUND OF DENIAL OF HIS RIGHT TO SPEEDY TRIAL
CONSTITUTES FINAL DISMISSAL OF cases.
Held:
No. Co failed to show any evidence that the alleged "vexatious, capricious and oppressive"
delay in the trial was attended with malice or that the same was made without good cause or justifiable
motive on the part of the prosecution. This Court has emphasized that "speedy trial is a relative term
and necessarily a flexible concept. In determining whether the accused's right to speedy trial was
violated, the delay should be considered in view of the entirety of the proceedings. The factors to
balance are the following: (a) duration of the delay; (b) reason therefor; (c) assertion of the right or
failure to assert it; and (d) prejudice caused by such delay.