G.R. No. L-6050, March 3, 1911
THE UNITED STATES vs. EMILIANO RAMOS, LUIS RAMOS and SEGUNDO RAMOS

FACTS

On April 5, 1909, Antonio Punsalan and his sons Elias and Perfecto were at a fishpond in Calumpit, Bulacan. Emiliano Ramos approached and told them to stop fishing, claiming his father Segundo Ramos owned the pond. After a dispute, Emiliano left and returned with his father Segundo and brother Luis. During the ensuing argument, Emiliano, positioned behind the seated and unarmed Perfecto, suddenly struck him in the back with a bolo. As Perfecto turned, Emiliano struck him again in the face. Elias intervened and disarmed Emiliano, but Luis then struck Elias on the head. While Perfecto lay mortally wounded on the ground, Segundo attacked and stabbed him in the abdomen. A bystander, Sabino de Leon, who tried to pacify the group, was also attacked and wounded by Luis and Segundo. Perfecto died from his wounds. The appellants were convicted of murder by the trial court.

ISSUE

1. Whether the appellants Emiliano, Luis, and Segundo Ramos are all liable as principals for the crime of murder.
2. Whether Luis and Segundo Ramos should be held liable for the qualifying circumstance of treachery (alevosia) employed by Emiliano.

RULING

The Supreme Court AFFIRMED the conviction.

1. All three appellants are principals in the crime. Under Article 13 of the Penal Code, not only those who directly execute the act are liable, but also those who cooperate by acts without which the crime would not have been accomplished. All three accused took direct part in the concerted attack that resulted in Perfecto’s death. Emiliano initiated the treacherous assault. Segundo delivered the fatal wound to the abdomen while Perfecto was helpless. Luis prevented Elias from aiding his brother by attacking him. Their actions constituted direct cooperation.

2. Luis and Segundo Ramos are equally liable for the qualifying circumstance of treachery. Although Luis and Segundo did not personally deliver the initial treacherous blow, they were present, witnessed Emiliano’s attack, and took advantage of its results to continue their own assault on the victims. By sanctioning Emiliano’s act and exploiting the helpless condition of Perfecto caused by that treachery, they are imputed with the same alevosia. The crime committed by all three is therefore murder, qualified by treachery.

The judgment of the trial court convicting the appellants of murder and sentencing each to cadena perpetua is affirmed.