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CAMILLE ANNE DAVID MARCH 13, 2017 G.R. NO. 225965

MARCH 13, 2017 G.R. NO. 214536

MARCH 13, 2017 G.R. NO. 225608


MARCH 13, 2017 G.R. NO. 226475

MARCH 15, 2017 G.R. NO. 213390

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MARTONE EMILE DESALES MARCH 22, 2017 G.R. NO. 215742

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MARCH 27, 2017 G.R. NO. 206590

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G.R. NO. 220598/G.R. NO.


APRIL 18, 2017 220953

NICOLETTE HENSON APRIL 26, 2017 G.R. NO. 207776

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JUNE 5, 2017 G.R. NO. 216063

JUNE 5, 2017 G.R. NO. 216937

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KIM LAMBERT MATIC
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ARLENE DANE SALAS
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HEIDI SUGAMOTO JUNE 19, 2017 G.R. NO. 220977

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MIGUEL TUASON JUNE 28, 2017 G.R. NO. 224143

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CASE TITLE BAR SUBJECT SUBJECT

XXX Criminal Law Felonies

gests. Just add 3 more columns


olumn as well.
main issue.
nts and suggestions.
PEOPLE OF THE PHILIPPINES VS. PUYAT Criminal Law Special Law
MACAPUNDAG Y LABAO

MEDEL CORONEL Y SANTILLAN, ET AL. VS. PEOPLE Criminal Law Special Law
OF THE PHILIPPINES

PEOPLE OF THE PHILIPPINES VS. ALBERTO


ALEJANDRO Y RIGOR AND JOEL ANGELES Y DE Criminal Law RPC Book II
JESUS
PEOPLE OF THE PHILIPPINES VS. CYRUS
VILLANUEVA Y ISORENA ALIAS "TUTOY" AND ALVIN Criminal Law RPC Book II
SAYSON Y ESPONCILLA ALIAS "ALVIN TALANGKA"

PEOPLE OF THE PHILIPPINES VS. JESSIE GABRIEL Y Criminal Law RPC Book II
GAJARDO

PEOPLE OF THE PHILIPPINES VS. NESTOR M. Criminal Law Felonies


BUGARIN
NICOLAS VELASQUEZ AND VICTOR VELAQUEZ VS. Criminal Law Felonies
PEOPLE OF THE PHILIPPINES
PEOPLE OF THE PHILIPPINES VS. PALA TOUKYO Y Criminal Law Criminal and Civil Liabilities
PADEP

PEOPLE OF THE PHILIPPINES VS. CHRISOPHER Criminal Law Felonies


MEJARO ROA
PEOPLE OF THE PHILIPPINES VS. ANASTACIO Criminal Law Special Law
HEMENTIZA Y DELA CRUZ

PEOPLE OF THE PHILIPPINES VS. JOSE BELMAR


UMAPAS Y CRISOSTOMO

PEOPLE OF THE PHILIPPINES VS. ARIEL S. MENDOZA

PEOPLE OF THE PHILIPPINES VS. MYRA GAYOSO Y


ARGUELLES
PEOPLE OF THE PHILIPPINES VS. JESUSANO
ARCENAL Y AGUILAN
PEOPLE OF THE PHILIPPINES VS. JUANITO
ENTRAMPAS
PEOPLE OF THE PHILIPPINES VS. KING REX A.
AMBATANG
PEOPLE OF THE PHILIPPINES VS. TIRSO SIBBU
ROBERTO P. FUENTES VS. PEOPLE OF THE
PHILIPPINES
EDUARDO QUIMVEL Y BRAGA VS. PEOPLE OF THE
PHILIPPINES

GLORIA MACAPAGAL-ARROYO VS. PEOPLE OF THE


PHILIPPINES AND THE SANDIGANBAYAN/BENIGNO
B. AGUAS VS. SANDIGANBAYAN

PEOPLE OF THE PHILIPPINES VS. GEORGE GACUSAN

PEOPLE OF THE PHILIPPINES VS. PORFERIO CULAS Y


RAGA
PEOPLE OF THE PHILIPPINES VS. MARLON SORIANO
Y NARAG
PEOPLE OF THE PHILIPPINES VS. TITO AMOC Y
MAMBATALAN
PEOPLE OF THE PHILIPPINES VS. ROLANDO BISORA
Y LAGONOY
PEOPLE OF THE PHILIPPINES VS. WILFREDO
PACAYRA Y MABUTOL

PEOPLE OF THE PHILIPPINES VS. HENRY BENTAYO

PEOPLE OF THE PHILIPPINES VS. SALVADOR


AYCARDO
PEOPLE OF THE PHILIPPINES VS. RICHARD F.
TRIPOLI AND ROMULO B. IMPAS
PEOPLE OF THE PHILIPPINES VS. JOSE DESCARTIN,
JR. Y MERCADER
PEOPLE OF THE PHILIPPINES VS. ALBERTO
FORTUNA ALBERCA
PEOPLE OF THE PHILIPPINES VS. RAFAEL AGUDO Y
DEL VALLE
PEOPLE OF THE PHILIPPINES VS. GODOFREDO
MACARAIG Y GONZALES
PEOPLE OF THE PHILIPPINES VS. JONATHAN BAAY Y
FALCO
PEOPLE OF THE PHILIPPINES VS. STEPHAN CABILES
Y SUAREZ A.K.A. "KANO"
PEOPLE OF THE PHILIPPINES VS. JOSE CUTURA Y
BRIX
PEOPLE OF THE PHILIPPINES VS. LORENZO RAYTOS
Y ESPINO
PEOPLE OF THE PHILIPPINES VS. SANDY DOMINGO
Y LABIS
PEOPLE OF THE PHILIPPINES VS. BLAS GAA Y
RODRIGUEZ
PEOPLE OF THE PHILIPPINES VS. ELMER AVANCENA
Y CABANELA, ET AL.
ANTHONY DE SILVA CRUZ VS. PEOPLE OF THE
PHILIPPINES
PEOPLE OF THE PHILIPPINES VS. PABLO LUAD
ARMODIA
PEOPLE OF THE PHILIPPINES VS. MERCEDITAS
MATHEUS Y DELOS REYES
PEOPLE OF THE PHILIPPINES VS. ALLAN JAO Y
CALONIA AND ROGELIO CATIGTIG Y COBIO
PEOPLE OF THE PHILIPPINES VS. AMBROSIO
OHAYAS, ET AL.
P/C SUPT. EDWIN A. PFLEIDER VS. PEOPLE OF THE
PHILIPPINES
PEOPLE OF THE PHILIPPINES VS. DEMETRIO SABIDA
Y SADIWA
PEOPLE OF THE PHILIPPINES VS. BILLIE GHER
TUBALLAS Y FAUSTINO
PEOPLE OF THE PHILIPPINES VS. WILTON ALACDIS Y
ANATIL A.K.A. "WELTON", DOMINGO LINGBANAN,
AND PEPITO ANATIL ALACDIS

NESTOR GUELOS, ET AL. VS. PEOPLE OF THE


PHILIPPINES
PO1 CELSO TABOBO III Y EBID VS. PEOPLE OF THE
PHILIPPINES
PEOPLE OF THE PHILIPPINES VS. ROBERTO
ESPERANZA JESALVA ALIAS "ROBERT SANTOS"

ESTATE OF HONORIO POBLADOR, JR. REPRESENTED


BY RAFAEL A. POBLADOR VS. ROSARIO L. MANZANO

CORAZON M. LACAP VS. SANDIGANBAYAN (FOURTH


DIVISION) AND THE PEOPLE OF THE PHILIPPINES

PEOPLE OF THE PHILIPPINES VS. JEFFREY


MACARANAS Y FERNANDEZ
PEOPLE OF THE PHILIPPINES VS. NICOLAS TUBILLO Y
ABELLA
RICHARD ESCALANTE VS. PEOPLE OF THE
PHILIPPINES
PEOPLE OF THE PHILIPPINES VS. RODOLFO
DENIEGA Y ESPINOSA
PEOPLE OF THE PHILIPPINES VS. MICHELLE DELA
CRUZ
VIRGILIO LABANDRIA AWAS VS. PEOPLE OF THE
PHILIPPINES
KEVIN BELMONTE Y GOROMEO VS. PEOPLE OF THE
PHILIPPINES
PEOPLE OF THE PHILIPPINES VS. NORIETO
MONROYO Y MAHAGUAY
MARLON BACERRA Y TABONES VS. PEOPLE OF THE
PHILIPPINES

PEOPLE OF THE PHILIPPINES VS. JOSEPH SAN JOSE Y


GREGORIO AND JONATHAN SAN JOSE Y GREGORIO

PEOPLE OF THE PHILIPPINES VS. EDGAR ALLAN


CORPUZ Y FLORES

MANILA BULLETIN PUBLISHING CORPORATION AND


RUTHER BATUIGAS VS. VICTOR A. DOMINGO AND
THE PEOPLE OF THE PHILIPPINES

PEOPLE OF THE PHILIPPINES VS. ALEX AMARY Y


MONTANO
PEOPLE OF THE PHILIPPINES VS. ROMMEL
DIPUTADO
PEOPLE OF THE PHILIPPINES VS. LUTHER SABADO
ET.AL
PEOPLE OF THE PHILIPPINES VS. MARLON
BELMONTE Y SUMANGIT, ET AL
TOPIC

Criminal Liabilities and Felonies


Comprehensive Dangerous Drugs Act (R.A. No. 9165)

Comprehensive Dangerous Drugs Act (R.A. No. 9165)

Crimes against Persons (RAPE & HOMICIDE)


Crimes against Persons (MURDER)

Crimes against Persons (RAPE)

Circumstances affecting Criminal Liability


Circumstances affecting Criminal Liability
Extinction of Criminal Liabilities

Circumstances affecting Criminal Liability


Comprehensive Dangerous Drugs Act (R.A. No. 9165)
SUB-TOPIC PONENTE

Classifications of felonies XXX


Comprehensive Dangerous Drugs Act (R.A. No. 9165) PERLAS-BERNABE, J.

Comprehensive Dangerous Drugs Act (R.A. No. 9165) LEONEN, J.

Crimes against Persons (RAPE & HOMICIDE) PERLAS-BERNABE, J.


Crimes against Persons (MURDER) REYES, J.

Crimes against Persons (RAPE) DEL CASTILLO, J.

Justifying Circumstances PERALTA, J.


Justifying Circumstances LEONEN, J.
Extinction of Criminal Liabilities PERLAS-BERNABE, J.

Exempting Circumstances VELASCO, JR.,J.


Comprehensive Dangerous Drugs Act (R.A. No. 9165) MENDOZA, J.
FACTS

XXX
Two (2) criminal cases were filed against the accused (Puyat) for violating Sections 5
and 11, Article II of RA 9165, for illegal sale and illegal possession of dangerous drugs
(EPHEDRINE), respectively. The prosecution presented that Police Chief Inspector (PCI)
Christopher Prangan (PCI Prangan) ordered the conduct of a buy-bust operation in
coordination with the Philippine Drug Enforcement Agency (PDEA) and other police
officers. They caught in Popoy in the act and PO3 Ardedon marked the plastic sachet
he purchased from Macapundag, while SPO1 Victoriano marked the other three (3)
recovered from his pocket. Thereafter, they brought Macapundag to the police
station, where the seized items were turned over to PO2 Randulfo Hipolito (PO2
Hipolito), the investigator on duty. Later, PO2 Hipolito brought the items to the crime
laboratory for physical examination. Eventually, Forensic Chemical Officer-PCI Stella
Ebuen (PCI Ebuen) examined the specimen, which tested positive for ephedrine, a
dangerous drug. The accused prayed for his acquittal claiming that they did not make
any inventory and failed to take pictures of the confiscated drugs along with him at
the scene of his arrest. There was also no justification given as to why they failed to
comply with these requirements of law.

Two (2) informations were filed against the accused-petitioners (Coronel, Permejo,
Villafuerte, Olivarez) for violating Article II, Sections 7 and 15 of Republic Act No. 9165
(Comprehensive Dangerous Drugs Act of 2002), for knowingly and illegally visiting a
drug den and using methamphetamine hydrochloride (shabu) respectively. The
petitioners stress that prosecution's failure to establish both a continuous and
unbroken chain of custody of the subject evidence, that the house, where petitioners
were apprehended, was a drug den, or that petitioners were aware that said house
was a drug den and that they visited it knowingly. Respondent apparently maintains
that because the petitioners' drug tests were conducted right after their arrest, it was
proven that drugs were used at the drug den itself. Moreover, the use of drugs at a
drug den automatically implies that the drug users were aware of the nature of the
place as a drug den before visiting it.

A total of three (3) separate Informations were filed against accused-appellants


(Alejandro & Angeles) of one (1) count of Simple Rape and one (1) count of Homicide ,
defined and penalized under Articles 335 and 249 of the Revised Penal Code (RPC),
respectively. The prosecution alleged that AAA joined BBB (co-worker) for a vacation
in Nueva Ecija and she (AAA) became witness in the case were BBB was raped &
killed. Alejandro & Angeles denied the charges against him and presented an alibi.
The accused-appellants (Villanueva & Sayson) were charged in the crime of murder
alleging that they are armed with a knife, with intent to kill and with the presence of
the qualifying circumstance of abuse of superior strength, conspiring and
confederating with one another did then and there wilfully, unlawfully, and
feloniously attack, assault and stab one, Enrico Enriquez y Vinluan on the left side of
his chest, thus causing fatal injury which directly caused his death. However, they
contented that RTC improperly appreciated the qualifying circumstance of abuse of
superior strength.

Appellant was indicted for rape in an Information which alleged that by force and
intimidation, did then and there, willfully, unlawfully and criminally, have carnal
knowledge upon one ["AAA"], a 17-year old minor, against her will and consent, to
the damage and prejudice of the latter. AAA testifies for herself and the appellant
denies charges against him and contended AAA was motivated by revenge because he
had accused her of stealing and insisted that she admit the act.

The accused-appellant armed with an unlicensed firearm, shot his brother-in-law


Esmeraldo B. Pontanar, father-in-law Cristito C Pontanar, and Maria Glen Neis
Pontanar, wife of Esmeraldo Pontanar. Only Maria Glen survived because she was
only shot in her thigh. Informations were filed charging Bugarin with two (2) counts of
murder and one (1) count of attempted murder. Upon arraignment, he pleaded not
guilty to the charges. The accused-appellant admitted having shot the victims but
insisted that he acted in self-defense.
Petitioners (Nicolas,Victor), along with four (4) others - (Felix, Jojo, Sonny, and
Ampong)- were charged with attempted murder under Article 248,in relation to
Article 6,of the Revised Penal Code. All accused, except Ampong, who remained at
large, pleaded not guilty upon arraignment. Petitioners invoke the first and second
justifying circumstances under Article 11 of the Revised Penal Code.
An Information was filed charging Toukyo of Illegal Sale of Dangerous Drugs. However,
it appears from the records that in a letter,Director General Atty. Benjamin C. De Los
Santos of the Bureau of Corrections informed the Court that Toukyo had already died
attaching thereto a Certification issued by Mr. Jose Ramon C. Padua, the Bureau's
Officer-in-Charge for its Rehabilitation Operations Division, as well as the Death
Report issued on even date by Dr. Ursicio D. Cenas, Medical Officer III of the same
Bureau.

An Information filed against accused-appellant Christopher Mejaro Roa (Roa) on June


5, 2007, charging him for the murder of Eliseo Delmiguez (Delmiguez), with intent to
kill and without justifiable cause, did then and there willfully, unlawfully, and
feloniously attack, assault, and stab Eliseo Delmiguez with the use of a bladed
weapon, locally known as "ginunting," hitting and injuring the body of the latter,
inflicting multiple mortal hack wound[s] thereon, which were the immediate and
direct cause of his instantaneous death. However, it was alleged that the accused
(Roa) is known to have suffered mental disorder prior to his commission of the crime
charged.
Accused was charged for violating Sections 5 and 11, Article II of RA 9165, for illegal
sale and illegal possession of dangerous drugs, respectively. It was explained that
police had adequately established the conduct of the buy-bust operation which
resulted in the consummated sale of the illegal drugs and the recovery of two (2)
sachets and the marked money in his possession. RTC & CA added that failure to
strictly comply with the provisions of Section 21 (1), Article II of R.A. No. 9165, on the
handling of confiscated illegal drugs, as well as its IRR, was not fatal and would not
render accused-appellant's arrest illegal or the items seized from him inadmissible.
ISSUE

XXX
Whether or not Macapundag's conviction for illegal sale and illegal p

Whether or not the prosecution has established that petitioners know

Whether or not Angeles is guilty beyond reasonable doubt of the


simple rape and homicide.
Whether or not accused-appellants are guilty of the crime of
murder.

Whether or not the testimony of AAA should give credence and


accused is guilty of the rape.

Whether or not the accused-appellant’s claim of self-defense is valid.


Whether or not there was sufficient evidence to prove the justifying
Whether or not Toukyo’s criminal liability is extinguished.

Whether or not insanity as exempting circumstance should be


considered.
Whether or not the guilt of the accused for the crimes charged has
been proven beyond reasonable doubt.
RULING/DOCTRINE

XXX
No, Section 21, Article II of RA 9165 provides the chain of custody rule, outlining the procedure police
officers must follow in handling the seized drugs, in order to preserve their integrity and evidentiary
value. Under the said section, the apprehending team shall, immediately after seizure and confiscation
conduct a physical inventory and photograph the seized items in the presence of the accused or the
person from whom the items were seized, his representative or counsel, a representative from the
media and the Department of Justice, and any elected public official who shall be required to sign the
copies of the inventory and be given a copy of the same, and the seized drugs must be turned over to
the PNP Crime Laboratory within twenty-four (24) hours from confiscation for examination.
In this case, the prosecution was able to establish that PO3 Ardedon (with respect to the sachet
handed over by Macapundag to him) and SPO1 Victoriano (with respect to the three sachets recovered
from Macapundag upon his arrest) marked the seized items immediately at the place of arrest.
However, the prosecution's witnesses failed to state whether or not the police officers inventoried and
photographed the seized sachets in the presence of Macapundag or his representative. Likewise, they
were silent as to the presence of the other required witnesses, i.e., a representative from the
Department of Justice (DOJ), any elected public official, and a member of the press.

No, there is no basis to assume that petitioners used drugs at the moment immediately before arrest,
and thus, at the location of the arrest. Assuming that persons who test positive for drugs used them at
the place of arrest is not sufficient to show that they were aware of the nature of the suspected drug
den before visiting it, absent any other circumstantial evidence. There were no acts alleged or evidence
found, which would tend to show a familiarity with the nature of the place as a drug den.
As to simple rape, No ; As to homicide, Yes. Elements of homicide: (1) that a person was killed; (2) that
the accused killed that person without any justifying circumstance; (3) that the accused had the
intention to kill, which is presumed; and (4) that the killing was not attended by any of the qualifying
circumstances of murder, or by that of parricide or infanticide. Moreover, the offender is said to have
performed all the acts of execution if the wound inflicted on the victim is mortal and could cause the
death of the victim without medical intervention or attendance.
The elements of Rape are: (a) the offender had carnal knowledge of the victim; and (b) said carnal
knowledge was accomplished through the use of force or intimidation; or the victim was deprived of
reason or otherwise unconscious; or when the victim was under twelve (12) years of age or demented.
The provision also states that if the act is committed either with the use of a deadly weapon or by two
(2) or more persons, the crime will be Qualified Rape, necessitating the imposition of a higher penalty.
Article 335 of the RPC states that if the rape is committed under certain circumstances, such as when it
was committed by two (2) or more persons, the crime will be Qualified Rape, as in this instance.
As to simple rape, No ; As to homicide, Yes. Elements of homicide: (1) that a person was killed; (2) that
the accused killed that person without any justifying circumstance; (3) that the accused had the
intention to kill, which is presumed; and (4) that the killing was not attended by any of the qualifying
circumstances of murder, or by that of parricide or infanticide. Moreover, the offender is said to have
performed all the acts of execution if the wound inflicted on the victim is mortal and could cause the
death of the victim without medical intervention or attendance.
The elements of Rape are: (a) the offender had carnal knowledge of the victim; and (b) said carnal
knowledge was accomplished through the use of force or intimidation; or the victim was deprived of
reason or otherwise unconscious; or when the victim was under twelve (12) years of age or demented.
The provision also states that if the act is committed either with the use of a deadly weapon or by two
(2) or more persons, the crime will be Qualified Rape, necessitating the imposition of a higher penalty.
Article 335 of the RPC states that if the rape is committed under certain circumstances, such as when it
was committed by two (2) or more persons, the crime will be Qualified Rape, as in this instance.
No, only homicide. The following essential elements must be present in order to warrant a conviction
for the crime of murder: 1. that a person was killed; 2. that the accused killed him or her; 3. that the
killing was attended by any of the qualifying circumstances mentioned in Article 248 of the RPC; and 4.
that the killing is not parricide or infanticide. One of the circumstances mentioned in Article 248, which
qualifies the killing of the victim to murder is abuse of superior strength.
In this case, the SC stated that the prosecution failed to present evidence as regards the relative
disparity in age, size, strength or force between the accused-appellants and Valencia, on one hand, and
Enrico, on the other. Indeed, the lower courts merely inferred the existence of qualifying circumstance
of abuse of superior strength on the facts that Enrico was attacked by three assailants, the accused-
appellants and Valencia, who were armed with a knife and a stone. However, mere superiority in
numbers does not ipso facto indicate an abuse of superior strength.

Yes, In the 1901 case of United States v. Ramos, this Court had already declared that when a woman
testifies that she has been raped she says, in effect, that all that is necessary to constitute the
commission of this crime has been committed. It is merely a question then, whether or not this court
accepts her statement." Jurisprudence has clung with unrelenting grasp to tills precept.
Appellant's denial cannot prevail over "AAA's" direct positive and categorical assertion that rings with
truth. Denial is inherently a weak defense which cannot outweigh positive testimony. As between a
categorical statement that has the earmarks of truth on the one hand and bare denial, on the other,
the former is generally held to prevail.

shooting of the victims, the burden shifted to Bugarin to prove that he indeed acted in self-defense by
establishing the following with clear and convincing evidence: (1) Unlawful aggression on the part of
the victims; (2) reasonable necessity of the means employed to prevent or repel the aggression; and
(3) lack of provocation on his part. One who admits killing or fatally injuring another in the name of
self-defense bears the burden of proving the aforementioned elements. While all three elements must
concur, self-defense relies first and foremost on proof of unlawful aggression on the part of the victim.
If no unlawful aggression is proved, no self-defense may be successfully pleaded. Contrary to his
None, ARTICLE 11. Justifying Circumstances. - The following do not incur any criminal liability:
1. Anyone who acts in defense of his person or rights, provided that the following circumstances
concur:
First. Unlawful aggression;
Second. Reasonable necessity of the means employed to prevent or repel it;
Third. Lack of sufficient provocation on the part of the person defending himself.
2. Anyone who acts in defense of the person or rights of his spouse, ascendants, descendants, or
legitimate, natural or adopted brothers or sisters, or of his relatives by affinity in the same degrees, and
those by consanguinity within the fourth civil degree, provided that the first and second requisites
prescribed in the next preceding circumstance are present, and the further requisite, in case the
provocation was given by the person attacked, that the one making defense had no part therein.
It is settled that when an accused admits [harming] the victim but invokes self-defense to escape
criminal liability, the accused assumes the burden to establish his plea by credible, clear and
convincing evidence; otherwise, conviction would follow from his admission that he [harmed] the
victim. Self-defense cannot be justifiably appreciated when uncorroborated by independent and
competent evidence or when it is extremely doubtful by itself. Indeed, in invoking self-defense, the
burden of evidence is shifted and the accused claiming self-defense must rely on the strength of his
own evidence and not on the weakness of the prosecution.
Yes, Art. 89. How criminal liability is totally extinguished. - Criminal liability is totally extinguished:
1. By the death of the convict, as to the personal penalties; and as to pecuniary penalties, liability
therefore is extinguished only when the death of the offender occurs before final judgment.

1. Death of the accused pending appeal of his conviction extinguishes his criminal liability as well as
the civil liability based solely thereon. As opined by Justice Regalado, in this regard, "the death of the
accused prior to final judgment terminates his criminal liability and only the civil liability directly arising
from and based solely on the offense committed, i.e., civil liability ex delicto in senso strictiore."
2. Corollarily, the claim for civil liability survives notwithstanding the death of accused, if the same may
also be predicated on a source of obligation other than delict. Article 1157 of the Civil Code
enumerates these other sources of obligation from which the civil liability may arise as a result of the
same act or omission:
a) Law b) Contracts c) Quasi-contracts d) xxx e) Quasi-delicts
3. Where the civil liability survives, as explained in Number 2 above, an action for recovery therefor
may be pursued but only by way of filing a separate civil action and subject to Section 1, Rule 111 of
the 1985 Rules on Criminal Procedure as amended. This separate civil action may be enforced either
against the executor/administrator or the estate of the accused, depending on the source of obligation
upon which the same is based as explained above.
4. Finally, the private offended party need not fear a forfeiture of his right to file this separate civil
action by prescription, in cases where during the prosecution of the criminal action and prior to its
extinction, the private-offended party instituted together therewith the civil action. In such case, the
statute of limitations on the civil liability is deemed interrupted during the pendency of the criminal
case, conformably with provisions of Article 1155 of the Civil Code, that should thereby avoid any
apprehension on a possible privation of right by prescription.

No, Article 12. Circumstances which exempt from criminal liability. - The following are exempt from
criminal liability:

1. An imbecile or an insane person, unless the latter has acted during a lucid interval.

When the imbecile or an insane person has committed an act which the law defines as a felony
(delito), the court shall order his confinement in one of the hospitals or asylums established for
persons thus afflicted, which he shall not be permitted to leave without first obtaining the permission
of the same court
Accused-appellant argues that the presumption of sanity must not be applied in his case, because of
the rule that a person who has been committed to a hospital or to an asylum for the insane is
presumed to continue to be insane. In this case, however, it is noteworthy that while accused-
appellant was confined in a mental institution in 2001, he was properly discharged therefrom in 2002.
This proper discharge from his confinement clearly indicates an improvement in his mental condition;
otherwise, his doctors would not have allowed his discharge from confinement. Absent any contrary
evidence, then, the presumption of sanity resumes and must prevail.
Strict compliance with the chain of custody requirement, however, is not always the case. Hence, the
IRR of R.A. No. 9165 provides:
SECTION 21.(a) The apprehending officer/team having initial custody and control of the drugs shall,
immediately after seizure and confiscation, physically inventory and photograph the same in the
presence of the accused or the person/s from whom such items were confiscated and/or seized, or
his/her representative or counsel, a representative from the media and the Department of Justice
(DOJ), and any elected public official who shall be required to sign the copies of the inventory and be
given a copy thereof: Provided, that the physical inventory and photograph shall be conducted at the
place where the search warrant is served; or at the nearest police station or at the nearest office of the
apprehending officer/team, whichever is practicable, in case of warrantless seizures; Provided, further,
that non-compliance with these requirements under justifiable grounds, as long as the integrity and
the evidentiary value of the seized items are properly preserved by the apprehending officer/team,
shall not render void and invalid such seizures of and custody over said items.
In the case at bench, the prosecution failed to demonstrate substantial compliance by the
apprehending officers with the safeguards provided by R.A. No. 9165 as regards the rule on chain of
custody. To begin with, the records are bereft of any showing that an inventory of the seized items was
made. Neither does it appear on record that the apprehending team photographed the contraband in
accordance with law.
Further, People v. Dahil restated the links that the prosecution must establish in the chain of custody in
a buy-bust situation to be as follows: first, the seizure and marking, if practicable, of the illegal drug
recovered from the accused by the apprehending officer; second, the turnover of the illegal drug

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