Title
People vs. Reyes
Case
G.R. No. 12635
Decision Date
Sep 25, 1917
Vicente Reyes killed Guiseppe Goggiano with a baston during a card game quarrel. The Supreme Court upheld his homicide conviction, ruling the means and harm were proportionate, rejecting mitigating circumstances.

Case Digest (G.R. No. 12635)

Facts:

The United States v. Vicente Reyes, G.R. No. 12635, September 25, 1917, the Supreme Court (Arellano, C.J., Carson, Araullo, and Street, JJ., concurring), Malcolm, J., writing for the Court.

The accused, Vicente Reyes, killed a United States Army soldier named Guiseppe Goggiano during a quarrel arising from a game of cards. Reyes struck Goggiano on the head with a baston (stick), and the blow resulted in the soldier's death.

At trial the court found that Reyes did not act in self-defense, that neither aggravating nor mitigating circumstances obtained, and that the crime was homicide. The trial court sentenced Reyes to fourteen years, eight months, and one day of reclusion temporal with the accessory penalties provided by law, ordered indemnity of P500 to the heirs of Goggiano, and assessed costs.

Reyes appealed the conviction to the Supreme Court. His sole assignment of error urged that the trial court should have applied mitigating circumstance No. 3 of Article 9 of the Penal Code—namely, that the offender had no intention to cause so great a wrong as that committed—because, he claimed, the killing exceeded his intention. In reviewing the case the Court focused on witness credibility and on whether the implement and means used (a baston struck on the head) pre...(Subscriber-Only)

Issues:

  • Should the Supreme Court disturb the trial court's factual findings and credibility determinations in this case?
  • Did mitigating circumstance No. 3 of Article 9 of the Penal Code (lack of intent to cause so great a wrong) apply, so as to warrant reduction of li...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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