US vs. Valdez Digest

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US vs.

VALDEZ
GR No. L-16486, March 22, 1921

FACTS:
On November 29, 1919 while the steamer Vigan was anchored in the Pasig River, a small boat was sent
to raise its anchor. On board this boat is the accused, Calixto Valdez who, being in charge of the crew,
began to verbally abuse the men for raising the anchor slowly. One of the men named Venancio
Gargantel protested against the offensive remarks and said that they would be able to work better if
Valdez stops from insulting them. Valdez took this as an act of insubordination. Enraged and with a big
knife in hand, the accused immediately moved towards the boat’s bow where Gargantel is. Before he
could even reach Gargantel, the latter thought it best to leap into the river. No efforts were made to
rescue Gargantel right away since they were threatened by Valdez.

For the next three days, a friend of Gargantel searched for the body to no avail. His family and friends
had never seen him again even in his lodgings in Manila, thus eventually assuming that Gargantel has
drowned and died.

ISSUE:
Whether or not Calixto Valdez is responsible for Venancio Gargantel’s death.

HELD:
Yes, the Court held that Valdez is indeed responsible for the death of Venancio Gargantel.
Were it not for the looming danger of being stabbed by Valdez, the deceased would not have jumped
into the river. The Court is under the opinion that it is unimaginable to think that Gargantel survived the
incident. Thus, notwithstanding the facts that the accused did not actually inflict any injury to the
deceased and that the latter’s body was never found, there is no doubt that Valdez is liable for the crime
of homicide.
The trial judge considered as an attenuating circumstance the fact that the accused did not intend to
cause such a grave offense (par. 3, Art. 9 of the Revised Penal Code). The Court affirms the sentence of
reclusion temporal or 12 years and one day of imprisonment and remuneration worth P500 for the
family of the deceased, in accordance with Art. 59 of the Revised Penal Code.

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