G.R. No. L-11314; July 28, 1916
THE UNITED STATES, plaintiff-appellee, vs. THE MOROS LUKES (alias PAKIRA DATU), MANIGCAN, SANDO, and AMANI BULU, defendants-appellants.

FACTS:
On May 31, 1915, in Bakung, Cotabato, the four Moro defendantsLukes (alias Pakira Datu), Manigcan, Sando, and Amani Buluarmed with bladed weapons (krises, bolos, and kampilanes), attacked and killed one Mainding by inflicting multiple fatal wounds. The incident arose from a dispute over possession of a farm implement called a ligis, which was in Mainding’s possession. The defendants attempted to take the implement by force, leading to a physical altercation in which all participated. After a preliminary investigation, a complaint for homicide was filed in the Court of First Instance. The defendants pleaded not guilty, claiming self-defense, but admitted to killing Mainding. The trial court convicted all defendants of homicide and imposed varying prison sentences: Lukes (10 years of prision mayor), Manigcan and Sando (4 years of prision correccional each), and Amani Bulu (5 years of prision correccional). They were also ordered to indemnify the heirs of Mainding. The defendants appealed.

ISSUE:
Whether the trial court erred in convicting the defendants of homicide and in imposing the respective penalties.

RULING:
The Supreme Court affirmed the conviction but modified the penalties. The Court held that the defendants’ admission of killing Mainding, coupled with evidence of their collective attack, established their guilt beyond reasonable doubt. Their claim of self-defense was untenable, as the altercation stemmed from their unlawful attempt to seize the ligis by force instead of resorting to legal remedies. The Court found no aggravating or mitigating circumstances. However, it noted that the trial court failed to justify the disparate penalties and improperly applied Article 11 of the Penal Code (as amended by Act No. 2142 ), which considers the defendant’s degree of instruction and education for penalty mitigation.

Applying Article 11 in light of the defendants’ ignorance and the absence of aggravating circumstances, the Supreme Court ruled that the penalty should be imposed in the minimum degree of reclusion temporal, the prescribed penalty for homicide. Accordingly, the Court modified the sentence: each defendant was sentenced to twelve years and one day of reclusion temporal, with the accessory penalties under Article 59 of the Penal Code, and each to bear one-fourth of the costs. The conviction and indemnity were upheld.