Title
People vs. Felix Villorga
Case
G. R. No. 40023
Decision Date
Jun 7, 1934
Felix Villorga convicted for Nicolas Dolendo's death; Supreme Court affirmed but modified penalty to 1-4 years imprisonment, P1,000 indemnity, and subsidiary imprisonment if insolvent.
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Case Digest (G. R. No. 40023)

Facts:

  1. Parties Involved:

    • Plaintiff and Appellee: The People of the Philippine Islands.
    • Defendant and Appellant: Felix Villorga.
  2. Jurisdiction and Trial:

    • The Supreme Court of the Philippines acquired jurisdiction over the case.
    • The case was submitted for decision after consideration by the Court based on the record.
  3. Lower Court Decision:

    • The Court of First Instance of Iloilo issued a decision dated June 20, 1933.
    • The defendant, Felix Villorga, appealed this decision.
  4. Crime and Victim:

    • The case involved the death of Nicolas Dolendo.
    • The defendant was charged and convicted in connection with the death.
  5. Penalty and Indemnity:

    • The lower court sentenced the defendant to imprisonment and required him to indemnify the heirs of the deceased.
  6. Supreme Court Modification:

    • The Supreme Court affirmed the lower court's decision but modified the penalty.
    • The defendant was sentenced to imprisonment ranging from 1 year to 4 years.
    • He was also ordered to indemnify the heirs of Nicolas Dolendo in the sum of P1,000, with subsidiary imprisonment in case of insolvency.
  7. Costs:

    • The costs of the case amounted to P24.00, to be collected through summary proceedings.
  8. Remand:

    • The case was remanded to the Court of First Instance for further proceedings.

Issue:

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Ruling:

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Ratio:

  1. Jurisdiction and Due Process:

    • The Supreme Court confirmed that it had jurisdiction over the case and that due process was observed in the trial and appeal.
  2. Modification of Penalty:

    • The Court found the penalty imposed by the lower court to be excessive and modified it to a range of 1 to 4 years of imprisonment, ensuring proportionality to the crime committed.
  3. Indemnity and Subsidiary Imprisonment:

    • The requirement for indemnity was deemed appropriate to compensate the heirs of the deceased. Subsidiary imprisonment was included to ensure compliance in case of the defendant's insolvency.
  4. Costs:

    • The assessment of costs was upheld as reasonable and necessary for the administration of justice.
  5. Remand for Further Proceedings:

    • The remand to the Court of First Instance was necessary to address any remaining procedural matters and ensure the proper execution of the judgment.


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