G.R. No. L-32066, March 15, 1903
PEOPLE OF THE PHILIPPINE ISLANDS vs. GONA (Mansaca)

FACTS

The defendant, Gona, was charged with homicide for killing Mapudul. On the evening of October 26, 1928, during a reunion where alcoholic drinks were consumed, a quarrel ensued between Gona and another individual named Dunca. After Dunca and his companions left the house, Gona followed with the intent to assault Dunca. However, due to darkness and his intoxicated state, Gona mistakenly identified Mapudul as Dunca and inflicted a fatal bolo wound on Mapudul’s neck. The trial court convicted Gona of intentional homicide, considering the extenuating circumstance of non-habitual intoxication, and sentenced him to twelve years and one day of reclusión temporal.

ISSUE

Whether Gona should be convicted of intentional homicide or the lesser crime of homicide through negligence, given that he killed Mapudul by mistake, without intent to harm the deceased.

RULING

The Supreme Court affirmed the trial court’s decision, convicting Gona of intentional homicide. The Court held that a mistake in the identity of the victim does not mitigate criminal liability when the act was committed with malice and willful intent to kill. Citing United States vs. Mendieta, the Court ruled that erroneously killing one person instead of another does not relieve the accused of criminal responsibility for intentional homicide, nor does it constitute a mitigating circumstance. The penalty imposed by the lower court was upheld.