GR 1344; (January, 1904) (Digest)
G.R. No. 1344 : January 19, 1904
THE UNITED STATES, complainant-appellee, vs. VALENTIN TRONO, ET AL., defendants-appellants.
FACTS:
Late on February 4, 1903, the defendants, led by municipal police subinspector Valentin Trono and including Maximo Angeles and Timoteo Natividad, arrested Benito Perez and two companions on suspicion of stealing a revolver. The prisoners were taken to Sapang-Angelo, where Perez was severely beaten and ill-treated by Trono and Angeles, as heard by witnesses who testified to the sounds of blows and Perez’s groans and pleas. Perez was left unable to walk and had to be supported to the municipal building. After being discharged the next day due to lack of evidence, Perez, suffering from intense abdominal pain and difficulty urinating, was taken home by boat. He died the following morning, February 6, 1903. The trial court convicted the defendants of the lesser offense of lesiones menos graves (minor physical injuries).
ISSUE:
Whether the trial court erred in convicting the defendants of lesiones menos graves instead of homicide, given the evidence linking the ill-treatment to Perez’s death.
RULING:
Yes. The Supreme Court reversed the trial court’s judgment. The evidence conclusively established that the defendants Valentin Trono and Maximo Angeles directly participated in beating Benito Perez, which caused severe injuries leading to his death. Their actions constituted homicide. The Court found the aggravating circumstances of nighttime and abuse of superiority, compensated by the mitigating circumstance that the defendants did not intend to kill Perez but only to coerce a confession. Timoteo Natividad was found to be an accomplice, having provided aid and protection but not directly participating in the beating.
The defendants were sentenced as follows: Valentin Trono and Maximo Angeles to fourteen years, eight months, and one day of reclusion temporal; Timoteo Natividad to eight years and one day of prision mayor. All three were ordered to pay an indemnity of 500 pesos to the heirs of the deceased and the costs.