GR L 17530; (October, 1962) (Digest)
G.R. No. L-17530; October 30, 1962
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CAUSIANO ENOT and PABLO VIÑALON, defendants-appellants.
FACTS
The accused, Causiano Enot and Pablo Viñalon, pleaded guilty to an information charging them with the complex crime of robbery with multiple homicide and physical injuries. The charges stemmed from their actions on the night of July 8, 1960, in Masbate. Having conspired to rob the house of Macario Conje, they entered armed with bolos. Inside, they found Macario Conje, his wife Maximina Arreglado, and their children Santiaga, Monina, and the infant Baby Conje.
In accordance with their plan to eliminate obstacles, the accused, without any provocation, attacked all five occupants. They stabbed and hacked the victims, resulting in the instantaneous deaths of Macario, Maximina, Monina, and Baby Conje. Santiaga Conje survived but sustained a leg injury requiring extensive medical care. After the killings, the appellants proceeded to steal a trunk and a fighting cock valued at P35.00. The trial court, after a careful examination of the accused to ensure they understood their plea and the consequences, found them guilty.
ISSUE
Whether the trial court correctly imposed the death penalty upon the appellants.
RULING
Yes, the Supreme Court affirmed the imposition of the death penalty. The Court meticulously reviewed the aggravating and mitigating circumstances. The appellants’ claim of intoxication as a mitigating circumstance was rejected for lack of proof that they were so drunk as to lose reason or self-control. Lack of instruction was also correctly disregarded, as the fundamental wrongfulness of their acts was undeniable.
The Court adjusted the assessment of aggravating circumstances. It ruled that nocturnity should not be considered separately from treachery, as the nighttime was integral to the treacherous execution of the crime. However, the crime remained aggravated by treachery, evident premeditation, the use of superior strength, disregard of the victims’ sex and tender age, and the violation of dwelling. Against these multiple aggravating circumstances stood only the single mitigating circumstance of a plea of guilty. The Court was particularly compelled by the senseless and depraved cruelty of the crime, especially the hacking of an infant. The penalty was thus affirmed, with the modification that the appellants were ordered to pay indemnity to the heirs of each deceased victim.