Dela Cruz, April Kris D - Assignment 1
Dela Cruz, April Kris D - Assignment 1
Dela Cruz, April Kris D - Assignment 1
10. U.S. vs. Lagnason, G.R. No. 1582, March 28, 1904
In the case of U.S. vs. Lagnason, G.R. No. 1582, March 28, 1904, the Court held that
the acts committed by the defendant constituted a "levying of war". That if any person
or persons, owing allegiance to the United States of America, shall levy war
against them, or shall adhere to their enemies, giving them aid and comfort
within the United States or elsewhere, and shall be thereof convicted, on confession
in open court, or on the testimony of two witnesses to the same overt act of the treason
whereof he or they shall stand indicted, such person or persons shall be adjudged
guilty of treason against the United States, and shall suffer death. Lagnson was
held liable for treason under Section 1 and 3 of the Act . 292 of the Philippine Commission.
11. People vs. Go Tian Sek Santos, G.R. No. L-319, March 28, 1946
In the case of People vs. Go Tian Sek Santos, the accused, a political offender,
contends that as a Chinese citizen he cannot be legally charged of espionage. The Court,
denying the defendant’s claim, held that he may charged for espionage, a crime against
national security wherein allegiance is immaterial. Espionage, (Commonwealth
Act No. 616) a crime not conditioned by the citizenship of the offender, and
considered as an offense against national security.
12. U.S. vs. Lol-lo, G.R. No. 17958, February 27, 1922
In the case of U.S. vs. Lol-lo, G.R. No. 17958, February 27, 1922, the accused
contented that they cannot be tried and charged of piracy in the Court of First Instance of
Sulu based on the grounds that the offense charged was not within the jurisdiction of the
Court of First Instance, nor of any court of the Philippine Islands, and that the facts did not
constitute a public offense, under the laws in force in the Philippine Islands. The contention
was overruled by the Judge.
The Court held that all of the elements of the crime of piracy are present. Piracy is
robbery or forcible depredation on the high seas, without lawful authority and
done animo furandi, and in the spirit and intention of universal hostility. It is a
crime not against any particular state but against all mankind. It may be
punished in the competent tribunal of any country where the offender may be
found or into which he may be carried. The jurisdiction of piracy unlike all other
crimes has no territorial limits. As it is against all so may it be punished by all.
13. People vs. Tulin, et. al., G.R. No. 111709, August 30, 2001
In the case of People vs. Tulin, et. al., G.R. No. 111709, August 30, 2001, the Court
held that article 122 of the Revised Penal Code, before its amendment, provided that piracy
must be committed on the high seas by any person not a member of its complement nor a
passenger thereof. Upon its amendment by Republic Act No. 7659, the coverage of the
pertinent provision was widened to include offenses committed "in Philippine waters." On
the other hand, under Presidential Decree No. 532 (issued in 1974), the coverage of the
law on piracy embraces any person including "a passenger or member of the complement
of said vessel in Philippine waters." Hence, passenger or not, a member of the
complement or not, any person is covered by the law.
Republic Act No. 7659 neither superseded nor amended the provisions on
piracy under Presidential Decree No. 532. There is no contradiction between the two
laws. There is likewise no ambiguity and hence, there is no need to construe or interpret
the law. All the presidential decree did was to widen the coverage of the law, in
keeping with the intent to protect the citizenry as well as neighboring states
from crimes against the law of nations. Piracy under the Article 122, as amended, and
piracy under Presidential Decree No. 532 exist harmoniously as separate laws.
The Court also mentioned that piracy falls under Title One of Book Two of
the Revised Penal Code. As such, it is an exception to the rule on territoriality in
criminal law. The same principle applies even if Hiong, in the instant case, were charged,
not with a violation of qualified piracy under the penal code but under a special law,
Presidential Decree No. 532 which penalizes piracy in Philippine waters.
15. People vs. Siyoh, et. al., G.R. No. 57292, February 18, 1986
In the case of People vs. Siyoh, et. al., G.R. No. 57292, February 18, 1986, the
number of the persons killed on the occasion of is not material. P.D. No. 532 considers
qualified piracy, i.e. rape, murder or homicide is committed as a result or on the occasion
of piracy, as a special complex crime punishable by death regardless of the number of
victims.
16. People vs. Tolentino, G.R. No. L-29419, August 31, 1971
In the case of People vs. Tolentino, G.R. No. L-29419, August 31, 1971, the
Court that the weakness of the conclusion of the lower court that conspiracy
existed overlooked circumstances favorable to the appellant. What was
done by him did not entail the responsibility that the law imposes on a principal.
His criminal liability amounts at most to that of accomplice.
17. People vs. Corbes, G.R. No. 113470, March 26, 1997
In the case of People vs. Corbes, G.R. No. 113470, March 26, 1997, the Court held
that the evidence failed to meet the quantum of proof required by law to
establish conspiracy which jurisprudence dictates must be shown to exist as
clearly and convincingly as the commission of the crime itself. No less than
proof beyond reasonable doubt is required.