GR L 4418; (March, 1908) (Digest)

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📌 CORE DOCTRINE

“The Supreme Court held that a threat uttered in the heat of anger without evidence of persistence or intent to carry it out constitutes a misdemeanor under Article 589, No. 3 of the Penal Code, not a crime.”

💡 PLAIN ENGLISH SUMMARY

Estrada's angry threats with a gun scared Delgado, but since he didn't actually try to harm him later and even apologized, it was treated as a minor offense, not a serious crime. The court reduced his penalty to just a fine because the threat was impulsive and not followed through.

📜 LEGAL MAXIM

Actus non facit reum nisi mens sit rea | De minimis non curat lex

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FACTS:
On the night of May 17, 1907, Andres V. Estrada’s wife, Cecilia, entered a billiard room. Anastasio Delgado, present in the room, commented to a friend, “are women allowed to come into billiard rooms?” Cecilia took offense, and a quarrel ensued. Estrada, Cecilia’s husband, intervened. Although Delgado left and hid, Estrada went out, returned with a revolver, and began searching for Delgado, who, fearing harm, returned home. Later, two witnesses informed Delgado that Estrada was looking for him to kill him. Delgado, out of fear, remained in his house that night and the following day, as he was told Estrada was still searching for him, threatening to kill him wherever he found him. A complaint was filed, and the lower court sentenced Estrada to two months and one day of arresto, a fine of 1,301 pesetas, with subsidiary imprisonment, and costs. Estrada appealed this judgment.

ISSUE:
Whether the acts committed by Andres V. Estrada constitute a crime or merely a misdemeanor for uttering threats, and thus, what is the appropriate penalty.

RULING:
The Supreme Court reversed the judgment of the lower court. It ruled that the acts committed by Andres V. Estrada did not constitute a crime but merely a misdemeanor for uttering threats, as defined and punished by Article 589, No. 3, of the Penal Code. The Court acknowledged that Estrada made earnest threats in the heat of anger while armed with a revolver, causing Delgado to fear for his safety. However, it found no evidence that Estrada persisted in carrying out the threat on the following day. On the contrary, the brother of the injured party, Flaviano Delgado, testified that Estrada and his wife later called at his house to implore pardon, with Estrada alleging the threat was uttered unintentionally and without premeditation. Therefore, the Court concluded that the deed had only the characteristics of a misdemeanor.

Andres V. Estrada was sentenced to pay a fine of 125 pesetas, and in case of insolvency, to suffer subsidiary imprisonment at the rate of one day for every 15 pesetas unpaid, and to pay the costs of both instances.

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