G.R. No. 1605 : March 17, 1905
THE UNITED STATES, plaintiff-appellee, vs. SIMEON MANAYAO, ET AL., defendants-appellants.

FACTS:
Simeon Manayao and Angel Manayao were charged with the crime of homicidio for the death of Mateo Margarejo on the night of June 23, 1903, in Angat, Bulacan. The incident stemmed from a rivalry between Simeon Manayao and the deceased over a love affair. After an initial altercation in a store, the parties continued their quarrel on the road, which escalated into a physical fight. During the fight, Simeon Manayao drew a pocketknife and stabbed Mateo Margarejo in the side, inflicting a fatal wound from which Margarejo died hours later. The evidence, including the testimony of an eyewitness and Simeon’s own admission, conclusively established that Simeon delivered the fatal blow. Angel Manayao was present and took sides in the quarrel, but there was no evidence he participated in the stabbing or had prior knowledge of Simeon’s intent to use a knife. The trial court convicted both accused not of homicide but of inflicting a grave wound during a tumultuous quarrel.

ISSUE:
1. Whether the trial court correctly convicted both Simeon Manayao and Angel Manayao for the death of Mateo Margarejo.
2. Whether the crime was properly qualified and the penalty correctly imposed.

RULING:
The Supreme Court reversed the trial court’s decision.
1. As to Simeon Manayao: He was found guilty of the crime of homicidio (homicide). The killing was marked by the extenuating circumstance of arrebato and obcecación (a sudden burst of passion arising from a wordy quarrel) under Article 9(7) of the Penal Code, with no aggravating circumstances. He was sentenced to twelve years and one day of reclusión temporal, with the accessory penalties under Article 60, ordered to indemnify the heirs of the deceased with 500 pesos, and to pay one-half of the costs.
2. As to Angel Manayao: He was acquitted due to insufficient evidence. The proof showed only one fatal wound inflicted by Simeon. There was no evidence of concerted action or prior knowledge on Angel’s part that would make him liable as a principal or accomplice in the homicide. The costs de oficio were declared as to him.

The trial court erred in convicting the accused of a different crime (inflicting a grave wound) not supported by the facts and the law.