- Policeman Ural boxed and burned a prisoner named Felix Napola in a jail cell, causing Napola's death
- Ural claimed he found Napola on fire and helped put it out, but witnesses said Ural poured liquid on Napola and lit him on fire
- The court found Ural criminally liable for Napola's death even though he may not have intended to kill him, as he unlawfully inflicted wounds that caused the death
- Policeman Ural boxed and burned a prisoner named Felix Napola in a jail cell, causing Napola's death
- Ural claimed he found Napola on fire and helped put it out, but witnesses said Ural poured liquid on Napola and lit him on fire
- The court found Ural criminally liable for Napola's death even though he may not have intended to kill him, as he unlawfully inflicted wounds that caused the death
- Policeman Ural boxed and burned a prisoner named Felix Napola in a jail cell, causing Napola's death
- Ural claimed he found Napola on fire and helped put it out, but witnesses said Ural poured liquid on Napola and lit him on fire
- The court found Ural criminally liable for Napola's death even though he may not have intended to kill him, as he unlawfully inflicted wounds that caused the death
Topic Mitigating Circumstances Case No. No. L-30801. March 27, 1974 Case Name People v. Ural Ponente Aquino, J.
DOCTRINE Art. 13, Paragraph 3: The following are mitigating circumstances: (3) that the offender had no intention to commit so grave a wrong as that committed
SUMMARY Policeman Ural boxed a prisoner to death but didnt mean it
RELEVANT FACTS
Facts based on testimony of Brigido Alberio, former detention prisoner o He saw Policeman Ural inside the jail, boxing the detention prisoner, Felix Napola. Eventually, Napola collapsed on the floor and Ural even stepped on his prostate body o Ural went out of the cell and after a while returned with a bottle, then poured its contents over the boys and ignited it with a match and left the cell o Ural saw Alberio and warned him: You better keep quiet of what I have done. The municipal health officers certified that were it not for medical intervention, the burns would caused death (2nd degree burns which could have resulted to toxemia and tetanus infection) Napola died on August 25, 1966 due to burns According to Ural, he heard a scream for help from Napola and found the latters shirt in flames, which Ural removed with some assistance. Ural didnt summon a doctor because, according to Napola, the burns were not serious. BUT court believed Alberios testimony over Urals Fact 3.
ISSUE
W/N Ural is liable for his actions
RATIO DECIDENDI
Issue Ratio W/N Ural is liable for his YES actions 1. Under article 4 of the RPC: Criminal liability shall be incurred by any person committing a felony (delito) although the wrongful act done be different from that which he intended a. He who is the cause of the cause if the cause of the evil caused 2. US v Escalona: an individual who unlawfully inflicts wounds upon another person, which result in the death of the latter, is guilty of the crime of homicide, and the fact that the injured person did not receive proper medical attendance does not affect the criminal responsibility
University of the Philippines College of Law JTR, 1-D
3. Aggravating circumstance was appreciated Art. 14, par. 1: the accused took advantage of his public position 4. The trial court failed to appreciate the mitigating circumstance that the offender had no intention to commit so grave a wrong as that committed (Par. 3, Art. 13, RPC) a. Manifest from the proven facts that Ural had no intent to kill him. He only wanted to maltreat Napola may be because in his drunken condition, he was making a nuisance of himself inside the detention cell. When Ural realized the fearful consequences of his felonious act, he allowed Napola to secure medical treatment at the municipal dispensary. b. Lack of intent to commit so grave a wrong offsets the generic aggravating circumstance of abuse of his official position.
RULING
Affirmed trial courts judgement. Reclusion perpetua, which is the medium period of the penalty for murder.