Seminar III

Fundamental Moral Principles (Insights and their application to certain cases and jurisprudence)

Submitted to: Dr. James Piscos

Submitted by: Audris Bulatao November 8, 2013

Laws and principles are not for the times when there is no temptation: they are for such moments as this, when body and soul rise in mutiny against their rigour ... If at my convenience I might break them, what would be their worth? Charlotte Bront, Jane Eyre

THE FUNDAMENTAL MORAL PRINCIPLES

VALUE OF LIFE PRINICIPLE

Life should not be taken for granted. You could either go as Life is too short or Life is the longest thing you would ever have in this world. I know some people who get annoyed with the saying that life is too short because in reality, it is the opposite. What could have been more important than life itself? What Is Life1 is a 1944 non-fiction science book written for the lay reader by physicist Erwin Schrdinger. He focused on one important question: "how can the events in space and time which take place within the spatial boundary of a living organism be accounted for by physics and chemistry?" In lay mans definition, it is about the cause and effect.

Some of us are trying to know reality without admitting it is a mystery. I remember the good movie I have watched this year; it is the Life of Pi. It is a fantasy adventure novel by Yann Martel published in 2001. The protagonist, Piscine Molitor "Pi" Patel, a Tamil boy from Pondicherry, explores issues of spirituality and practicality from an early age. He survives 227 days after a shipwreck while stranded on a lifeboat in the Pacific Ocean with a Bengal tiger named Richard Parker2. Life of Pi, according to Yann Martel, can be summarized in three statements- "Life is a story... You can choose your story... A story with God is the better story."3 Religion, philosophy, and all human thought is just that, human thought. It is the product of human consciousness. We humans cannot know what real fact is nor be sure of it. Therefore myth and story is of the

1 2

Margulis, Lynn. & Sagan, Dorion. (1995). What Is Life? (pg. 1). Berkeley: University of California Press. "Life of Pi", http://en.wikipedia.org/wiki/Life_of_pi#Life_is_a_story accessed 10/31/2013 3 Renton, Jennie. "Yann Martel Interview". Textualities. Retrieved 19 May 2013.

greatest importance to how we survive in our lives. Religions are cultural phenomena. Every successful culture needs at least one successful religion and has at least one.

Self-preservation is behavior that ensures the survival of an organism. Fear causes the organism to seek safety and may cause a release of adrenaline. 4

As the Court pointed out in People v. Gadia5: "Where an accused invokes self-defense, the burden is shifted to him to prove that he killed the victim to save his life. For this reason he must rely on his own evidence and not on the weakness of the evidence for the prosecution, for such can no longer be disbelieved after the accused admits the killing. He must prove the presence of all the requisites of self-defense, namely: (1) unlawful aggression on the part of the victim; (2) reasonable necessity of the means employed to prevent or repel it; (3) lack of sufficient provocation on the part of the person defending himself. Of these requisites, the most decisive is that the victim was guilty of unlawful aggression. This is because the theory of self-defense is based on the necessity on the part of the person being attacked to prevent or repel the aggression. Hence, absent evidence of prior unlawful and unprovoked attack by the victim, the claim of self-defense cannot prosper."

An accused-appellant's allegation of self-defense when established solely by his testimony, and the he fail to corroborate his claim of self-preservation with evidence other than his own testimony, his plea of self-defense cannot be justifiably entertained where it is not only

uncorroborated by any separate competent evidence but is also extremely doubtful in itself. Succinctly stated, the Court will rule that it is a tal too riddled with loopholes to be believed. The Court has consistently held that to be credible, testimonial evidence should not only come from
4

Henry Gleitman, Alan J. Fridlund and Daniel Reisberg (2004). Psychology (6 ed.). W. W. Norton & Company. ISBN 0-393-97767-6. 5 G.R. No. 132384, 21 September 2001, pp. 17-18 (People v. Gadia)

the mouth of a credible witness but it should also be credible, reasonable and in accord with human experience. It is a well-settled rule that testimonial evidence to be believed must not only proceed from the mouth of a credible witness but must foremost be credible in itself. The test to determine the value or credibility of testimony of a witness is whether or not such is in conformity with common knowledge and consistent with the experience of mankind6.

Another point of view that received critics is the mercy killing. There was an interesting article entitled Man shoots sick wife in alleged 'mercy killing7. Is it really mercy killing or just plain murder? Euthanasia is categorized in different ways, which include voluntary, non-voluntary, or involuntary. Voluntary euthanasia is legal in some countries and U.S. states. Non-voluntary euthanasia is illegal in all countries. Involuntary euthanasia is usually considered murder.

The word "euthanasia" was first used in a medical context by Francis Bacon in the 17th century, to refer to an easy, painless, happy death, during which it was a "physician's responsibility to alleviate the 'physical sufferings' of the body." Bacon referred to an "outward euthanasia" the term "outward" he used to distinguish from a spiritual conceptthe euthanasia "which regards the preparation of the soul.8 Physician-assisted suicide is thus not classified as euthanasia by the US State of Oregon, where it is legal under the Oregon Death with Dignity Act, and despite its name, it is not legally classified as suicide either. Unlike physician-assisted suicide, withholding or withdrawing life-sustaining treatments with patient consent (voluntary) is almost unanimously considered, at least in the United States, to be legal. The use of pain medication in order to relieve suffering, even if it hastens death, has been held as legal in several court decisions.

6 7

G.R. Nos. 140557-58. December 5, 2001 (People v. Herrera)

Murder or Mercy (http://foxnewsinsider.com/2013/08/29/kentucky-man-ernest-chris-chumbley-claims-he-shotwife-end-cancer-suffering) 8 Francis Bacon: the major works By Francis Bacon, Brian Vickers pp 630.

Some governments around the world have legalized voluntary euthanasia but generally it remains as a criminal homicide. In the Netherlands and Belgium, where euthanasia has been legalized, it still remains homicide although it is not prosecuted and not punishable if the perpetrator (the doctor) meets certain legal exceptions9 There is a thin line between murder and mercy killing. However, as some of the jurisprudence says, each decision is particular to each case.

Ernest Chris Chumbley of London, Kentucky, openly admits to shooting his wife, and even called 911 Wednesday to report his actions. Now, he is facing murder charges for her death. Chumbley, 48, has pleaded not guilty and says his wife, Virginia, wanted to die. She had been battling breast cancer for a few years. He reportedly shot her multiple times with a handgun, killing her in their home. (Note: The trial is on going.)

Principle of Goodness or Rightness

To keep us sane in this world, we need values and principles to guide us along the way. We choose to be good because we believe in karma. We believe that if we do something good, somethings better is coming our way. There is no harm in believing in that. As long as you are not hurting anyone or yourself, you are good to go.

This principle operates between shall and will. The difference between the two is that "Shall" is a formal way to express intended future action. The traditional rule is that to express a simple

Oluyemisi Bamgbose (2004). "Euthanasia: Another Face of Murder". International Journal of Offender Therapy and Comparative Criminology 48 (1)

future tense shall is used after the first person. On the other hand, "Will" (in its verb form) is used to indicate future action for second or third-person.

Everything we do in life is a choice, and I think most of us realize that. But what most people dont seem to realize is that everything we dont do in life is also a choice. Every day we choose to do some things and to not do other things. We all know that we can change our life whenever we want to. But just wanting to change is not enough. We must make the choice to change. Many of us choose to do nothing but wish things would change. Consequently, nothing ever changes.

Such occurrences could result in a state of confusion but one should remember that we could always control our reactions. We are in complete control of our responses and decide what value any event has in our lives.

In a prosecution for libel with the publication of defamatory matter, in the absence of proof to the contrary, malice is always presumed. The burden of proving justifiable motives is upon the person responsible for the publication of the libel. Goodness of intention is not always sufficient to justify the publication of an injurious allegation of fact. The question of justifiable motive is one which must be decided by taking into consideration not only the intention but all the circumstances connected with the particular case. Another example is in People v. Agustin10, therein appellant argued that she could not be convicted of illegal recruitment because in introducing the complainants to the alleged recruiters, she merely acted "out of the goodness of her heart." In resolving said case, the Court ruled: The testimonial evidence hereon show that she indeed further committed acts constitutive of illegal recruitment. All four prosecution witnesses testified that it was Agustin whom they initially approached regarding their plans of
10

317 Phil. 897 (1995) (People v Agustin)

working overseas. It was from her that they learned about the fees they had to pay, as well as the papers that they had to submit. It was after they had talked to her that they met the accused spouses who owned the placement agency. As such, the Court concluded that appellant was an employee of the Goce spouses, as she was actually making referrals to the agency. She was, therefore, engaged in recruitment activities.

The term beneficence connotes acts of mercy, kindness, and charity. It is suggestive of altruism, love, humanity, and promoting the good of others11. In ordinary language, the notion is broad, but it is understood even more broadly in ethical theory to include effectively all forms of action intended to benefit or promote the good of other persons. The language of a principle or rule of beneficence refers to a normative statement of a moral obligation to act for the others' benefit, helping them to further their important and legitimate interests, often by preventing or removing possible harms.

Under Article 1274, of the Civil Code of 1889, liberality of the donor is deemed causa only in those contracts that are of "pure" beneficience that is to say, contracts designed solely and exclusively to procure the welfare of the beneficiary, without any intent of producing any satisfaction for the donor; contacts, in other words, in which the idea of self-interest is totally absent on the part of the transferor. For this very reason, the same Article 1274 provides that in remuneratory contracts, the consideration is the service or benefit for which the remuneration is given; causa is not liberality in these cases because the contract or conveyance is not made out of pure beneficience, but "solvendi animo".

Principle of Justice and Fairness

11

Gert, Bernard, 2005, Morality, New York: Oxford University Press.

Under this principle, I want to share some inspiring and latest jurisprudence about how justice and fairness was applied in some interesting cases.

THE INTENT OF THE STATUTE IS THE LAW. The intent of a statute is the law. If a statute is valid it is to have effect according to the purpose and intent of the lawmaker. The intent is the vital part, the essence of the law, and the primary rule of construction is to ascertain and give effect to the intent. The intention of the legislature in enacting a law is the law itself, and must be enforced when ascertained, although it may not be consistent with the strict letter of the statute. Courts will not follow the letter of a statute when it leads away from the true intent and purpose of the legislature and to conclusions inconsistent with the general purpose of the act. Intent is the spirit which gives life to a legislative enactment. In construing statutes the proper course is to start out and follow the true intent of the legislature and to adopt that sense which harmonizes best with the context and promotes in the fullest manner the apparent policy and objects of the legislature.- PANGANIBAN CJ. .in Philippine National Bank v. Office of the President12

JUDICIAL ETHICS, JUDGES; ADMINISTRATION OF JUSTICE SHOULD BE SPEEDY BUT CAREFUL. The Court exists to promote justice and, thus, aid in securing the contentment and happiness of the people. To this end, the judge should organize his or her court with a view to a prompt and convenient dispatch of business, especially those cases which the law requires to be expeditiously heard and decided. On the other hand, a judge should not decide cases with undue haste, especially when their nature and complexity require in-depth study and research. A fast-tracking in the disposition of cases to achieve popularity at the expense of mature and careful deliberation is anathema to justice and fairness. The administration of justice should be

12

322 Phil. 6, 14, January 18, 1996

speedy but, at the same time, careful. - Kapunan J. in UNITED BF HOMEOWNERS v. Gutierrez13

CONFLICT OF EVIDENCE; PRESUMPTION OF INNOCENCE; ACQUITTAL. When a marked conflict exists between the evidence of the prosecution and that of the defense, to such an extent that the mind is perplexed and very uncertain as to the innocence or the guilt of the accused, their responsibility not having been thoroughly established, and in case a reasonable doubt exists, the accused are entitled to an acquittal. - TORRES, J in US. v. Magno14

CRIMINAL PROCEDURE; ARRESTS, SEARCHES AND SEIZURES; WARRANT REQUIRED; EXCEPTIONS; NOT PRESENT IN CASE AT BAR. The general rule as regards arrests, searches and seizures is that a warrant is needed in order to validly effect the same. The Constitutional prohibition against unreasonable arrests, searches and seizure refers to those effected without a validly issued warrant, subject to certain exceptions found in Section 5, Rule 113 of the Rules of Court, which reads: "Section 5. Arrest without warrant; when lawful A peace officer or a private person may, without a warrant, arrest a person: a) When, in his presence the person to be arrested has committed, is actually committing, or is attempting to commit an offense; b) When an offense has in fact just been committed, and he has personal knowledge of facts indicating that the person to be arrested has committed it; and c) When the person to be arrested is a prisoner who has escaped . . . ." Not one of the above exceptions attended the arrest of appellants. Hence, the raid conducted on the premises by the police without any search warrant or warrant of arrest was illegal. Since the warrantless arrests were invalid, the search conducted on the premises was not one which is incidental to a lawful warrantless arrest. Thus, the search in the motel, without the benefit of a search warrant, was

13 14

A.M. No. CA-99-30. September 29, 1999 (United BF Homeowners v. Gutierrez) G.R. No. L-3517. August 7, 1907

clearly illegal and the shabu allegedly seized thereat are inadmissible in evidence against appellants.- Austria-Martinez J. in People v. Lim15

EVIDENCE; DISCOVERY PROCEDURES IN CRIMINAL CASES; TO STRENGTHEN THE CONSTITUTIONAL RIGHT OF ACCUSED TO DUE PROCESS. I write this opinion to complement the learned opinion of our Chief Justice. Thus, this Court has given an expensive interpretation of the right of an accused to discovery procedure. In the first Webb case, we held: ". . . This failure to provide discovery procedure during preliminary investigation does not, however, negate its use by a person under investigation when indispensable to protect his constitutional right to life; liberty and property. Preliminary investigation is not too early a stage to guard against any significant erosion of the constitutional right to due process of a potential accused. . . . We uphold the legal basis of the right of petitioners to demand from their prosecutor, the NBI, the original copy of the April 28, 1995 sworn statement of Alfaro and the FBI Report during their preliminary investigation considering their exculpatory character, and hence, unquestionable materiality to the issue of their probable guilt. The right is rooted on the constitutional protection of due process which we rule to be operational even during the preliminary investigation to a potential accused. . . ." Upon assumption of office, our present Chief Justice vowed to have a court that is pro-active, a stance that will surely promote rights more than authority. I am sure such a stance will quicken moves to liberalize further our rules on criminal procedure on the matter of discovery and deposition taking as to strengthen the constitutional right to due process of an accused. PUNO, J., concurring opinion: People v. Webb16

Principle of Truth Telling

G.R. No. 141699. August 7, 2002

16

We all grew up watching fairy tales and reading Charles Dickens Short stories about being a good person and a reward of good life thereafter. Who could forget the famous Pinocchio who is known for having a short nose that becomes longer when he is under stress, especially while lying?

The Paradoxical Commandments17 People are illogical, unreasonable, and self-centered. Love them anyway. If you do good, people will accuse you of selfish ulterior motives. Do good anyway. If you are successful, you will win false friends and true enemies. Succeed anyway. The good you do today will be forgotten tomorrow. Do good anyway. Honesty and frankness make you vulnerable. Be honest and frank anyway. The biggest men and women with the biggest ideas can be shot down by the smallest men and women with the smallest minds. Think big anyway. People favor underdogs but follow only top dogs. Fight for a few underdogs anyway. What you spend years building may be destroyed overnight. Build anyway. People really need help but may attack you if you do help them. Help people anyway. Give the world the best you have and you'll get kicked in the teeth. Give the world the best you have anyway.

I just love how the Paradoxical Commandments was written. It is about forgiveness, happiness, honesty, and goodness all in one. Honesty and frankness make you vulnerable. Be honest and
17

Kent M. Keith, The Silent Revolution: Dynamic Leadership in the Student Council

frank anyway. Sometimes, we hide our true selves and emotions because it makes us look weak, and exposed. But on the contrary, being honest shows strength and a lot of character.

In a different light, the conduct and behavior of everyone connected with an office charged with the dispensation of justice, from the presiding judge to the lowliest clerk, should be circumscribed with the heavy burden of responsibility. The strictest standard of honesty and integrity in the public service is required of those involved in the administration of justice. A court employee, being a public servant, must exhibit the highest sense of honesty and integrity not only in the performance of his official duties but in his personal and private dealings with other people, to preserve the court's good name and standing. Every employee of the judiciary should be an example of integrity, uprightness and honesty.

In the credibility of witnesses, minor matters do not impair the essential integrity of the prosecution evidence as a whole nor do they reflect on the witnesses' honesty. Differences in the recollection of details relating to the same incident may be expected from the several persons testifying thereon; but as long as there is basic agreement on the main points of the incident, their respective declarations may not be rejected as totally untrue.

Lawyers must conduct themselves, especially in their dealings with their clients and the public at large, with honesty and integrity in a manner beyond reproach. "To say that lawyers must at all times uphold and respect the law is to state the obvious, but such statement can never be overemphasized. Considering that, 'of all classes and professions, [lawyers are] most sacredly bound to uphold the law,' it is imperative that they live by the law. Accordingly, lawyers who violate their oath and engage in deceitful conduct have no place in the legal profession. "18

18

Citing Ex parte Wall, 107 U.S. 265, cited in Malcolm, Legal and Judicial Ethics, p. 214.

Principle of Individual Freedom

A judgment of conviction requires that the accused be shown to have been the perpetrator of the crime charged in the information by proof beyond reasonable doubt. Unless the accused is identified as the doer of the crime by such proof, the charge against the accused must be dismissed for the constitutional presumption of innocence has not then been overcome. In all criminal prosecutions, the accused shall be presumed to be innocent until the contrary is proved19.

Freedom means being able to think, choose, and act independently without constraint and is arguably one of the basic human rights. Total freedom of the individual, without a sense of responsibility or self-restraint, soon infringes on the freedom of others and therefore freedom of the individual in a society involves some measure of regulation and boundaries

Where a circumstance may yield two or more inferences, one consistent with the presumption of innocence and the other compatible with the finding of guilt, the Court must rule in favor of the accused. As shown in People v. Valdez20, Accused-appellant was found guilty by the trial court of simple rape for sexually abusing a seven-year old girl. He was sentenced to suffer the penalty of reclusion perpetua. Hence, the appeal. The Supreme Court held that the victim had actually been raped considering that she was suffering from a sexually transmitted disease. The absence of a laceration on her hymen does not negate rape. Nonetheless, the Court held that the evidence did not establish the identity of accused-appellant as the culprit. Whether or not accused-appellant was suffering from venereal disease is crucial to the case for the prosecution in view of its theory that appellant infected the victim with the disease when he raped her. In

19 20

Section 1 [17], Article III of the 1987 Constitution G.R. No. 145503. August 20, 2002

fact, the victim admitted that she had been raped only after she had been examined and pus had been found in her private parts. In this case, Dr. Llamas' testimony is not only that appellant was not suffering from gonorrhea but that he found no trace of it from an examination of appellant. Where a circumstance may yield two or more inferences, one consistent with the presumption of innocence and the other compatible with the finding of guilt, the Court must rule in favor of the accused. The Court is convinced that the victim had indeed been raped, but it is equally not convinced that it was accused-appellant who raped her. Appellant was acquitted on ground of reasonable doubt. The Supreme Court acquitted appellant on the ground of reasonable doubt.

Where the evidence on an issue of fact is in equipoise or there is doubt on which side the evidence preponderates, the party having the burden of proof fails upon that issue. Therefore, as neither party was able to make out a case, neither side could establish its cause of action and prevail with the evidence it had. They are thus no better off than before they proceeded to litigate, and, as a consequence thereof, the courts can only leave them as they are. In such cases, courts have no choice but to dismiss the complaints/petitions.

Briefly stated, the needed quantum of proof to convict the accused of the crime charged when found lacking; he must be declared innocent and set free. This is how our Constitution and criminal laws protects the rights of an accused.

It is the long standing policy of the Court that when the guilt of the accused has not been proven with moral certainty, the constitutional presumption of innocence of the accused must be favored and his exoneration granted as a matter of right regardless of the weakness or even the absence of his defense.

Principle of Double Effect and Principle of Proportionality

The principle of double effect is a set of ethical criteria which Christians, and some others, use for evaluating the permissibility of acting when one's otherwise legitimate act may also cause an effect one would normally be obliged to avoid. Double-effect originates in Thomas Aquinas's treatment of homicidal self-defense, in his work Summa Theologiae21.

An action that is good in itself that has two effects, first is the intended and otherwise not reasonably attainable good effect, and second, the an unintended yet foreseen evil effect--is licit, provided there is a due proportion between the intended good and the permitted evil. When there is a clash between the two universal norms of "do good" and "avoid evil," the issue arises as to whether or not the obligation to avoid evil requires one to abstain from a good action in order to prevent a foreseen but merely permitted evil effect.

Classical formulations of the principle of double effect require that four conditions be met if the conduct in question is to be ethically permissible. First: the action contemplated by the agent be in itself either ethically good or ethically indifferent (the principle of respect for the agent's autonomy). Second: that the evil consequence not be directly intended by the agent (the

principle of nonmalfeasance). Third: the good result not be a direct causal result of the evil result (the principle of beneficence). Fourth: the good result must be "proportionate to" the evil result (the principle of justice).

An example would be the case wherein a pregnancy may need to be terminated in order to preserve the life of the mother. The principle of double effect is alleged to allow the removal of

21

Summa Theologiae, IIa-IIae Q. 64, art. 7

a life-threatening cancerous uterus, even though this procedure will bring the death of a fetus, on the grounds that in this case the death of the fetus is not "directly" intended.

Jurisprudence holds that, when the accused admits committing the crime but invokes selfdefense to escape criminal liability, the burden of proof shifts to him. It necessarily follows that he must now rely on the strength of his own evidence and not on the weakness of that of the prosecution, for even if the latter's evidence is weak, it cannot be disbelieved after the accused has admitted the killing. He must then prove the following elements of self-defense: unlawful aggression on the part of the victim; reasonable necessity of the means employed to prevent or repel it and lack of sufficient provocation on the part of the one resorting to self-defense. Of these requisites, the most indispensable is unlawful aggression on the part of the victim. If there is no unlawful aggression, there is nothing to prevent or repel. And for unlawful aggression to be appreciated, there must be a strong and positive act of real aggression, not merely a threat or an intimidating stance. Thus, the accused who claims self-defense must positively establish that there was an actual, sudden and unexpected attack, or imminent danger thereof, by the victim.

In Jayme v. People22, In acquitting the petitioner of the charge of frustrated homicide, the Supreme Court held that petitioner acted in legitimate self-defense. The Court found that the petitioner had duly proved all the essential elements of self-defense. It ruled that petitioner employed reasonable means to repel the sudden unprovoked attack of which he was the victim. Under the above-mentioned situation, in the darkness of the night, with the element of surprise in the assault, and his perception that the aggressor was armed with a knife and together with three or more persons was ganging up on him, it was reasonable for petitioner to use a knife to disable his adversary. His knife was his only means of defense, and under the circumstances of the case there was clearly a reasonable necessity for him to make use of it. It cannot be said
22

G.R. No. 124506. September 9, 1999

with any certainty that his life was not in danger. Reasonable necessity does not mean absolute necessity. It is not the indispensable need but the rational necessity, which the law requires.

The rule of reasonable necessity is not ironclad in its application; it depends upon the circumstances of the particular case. One who is assaulted does not have the time nor sufficient tranquility of mind to think, calculate and choose the weapon to be used. The reason is obvious, in emergencies of this kind, human nature does not act upon processes of formal reason but in obedience to the instinct of self-preservation; and when it is apparent that a person has reasonably acted upon this instinct, it is the duty of the courts to sanction the act and to hold the actor irresponsible in law for the consequences.

Bibliography

Cases:

317 Phil. 897 1995 People v Agustin 322 Phil. 6, 14, January 18, 1996 Philippine National Bank v. Office of the President A.M. No. CA-99-30. September 29, 1999 United BF Homeowners v. Gutierrez G.R. No. 132384, 21 September 2001, pp. 17-18 People v. Gadia G.R. No. 140557-58. December 5, 2001 People v. Herrera G.R. No. 124506. September 9, 1999 Jayme v. People G.R. No. L-3517. August 7, 1907 US. v. Magno G.R. No. 141699. August 7, 2002 People v. Lim G.R. No. 132577. August 17, 1999 People v. Webb G.R. No. 145503. August 20, 2002 People v. Valdez

Others:

Citing Ex parte Wall, 107 U.S. 265, cited in Malcolm, Legal and Judicial Ethics, p. 214. Francis Bacon: the major works By Francis Bacon, Brian Vickers pp 630. Gert, Bernard, 2005, Morality, New York: Oxford University Press. Henry Gleitman, Alan J. Fridlund and Daniel Reisberg (2004). Psychology (6 ed.). W. W. Norton & Company. ISBN 0-393-97767-6. Kent M. Keith, The Silent Revolution: Dynamic Leadership in the Student Council "Life of Pi", http://en.wikipedia.org/wiki/Life_of_pi#Life_is_a_story accessed 10/31/2013 Margulis, Lynn. & Sagan, Dorion. (1995). What Is Life? (pg. 1). Berkeley: University of California Press.

Murder or Mercy (http://foxnewsinsider.com/2013/08/29/kentucky-man-ernest-chris-chumbleyclaims-he-shot-wife-end-cancer-suffering) Offender Therapy and Comparative Criminology 48 (1) Oluyemisi Bamgbose (2004). "Euthanasia: Another Face of Murder". International Journal of Offender Therapy and Comparative Criminology 48 (1) Section 1 [17], Article III of the 1987 Constitution Summa Theologiae, IIa-IIae Q. 64, art. 7 Renton, Jennie. "Yann Martel Interview". Textualities. Retrieved 19 May 2013