G.R. No. L-6116 / February 27, 1911
THE UNITED STATES, plaintiff-appellee, vs. ISIDORO ALIAS, ET AL., defendants-appellants.

FACTS

The appellants, Isidoro Alias, Benito Castro, and Brigido Binis, together with two others (who became prosecution witnesses), went at night to a house and captured Ponciano Miral. Alias, the leader, ordered Castro and Binis to tie Miral’s arms. Alias struck Miral and accused him of destroying his home, referencing a woman who had left Alias for Miral. Alias then ordered the others to take the bound prisoner away. Before they left, Alias whispered something to Binis. At a deserted hemp field, Castro struck the bound and defenseless Miral with a club, and Binis then stabbed him in the breast with a bolo, causing his death. The next morning, under Alias’s direction, they buried the corpse. The trial court convicted all three of asesinato (murder) and imposed the death penalty.

ISSUE

1. Whether the trial court correctly convicted the appellants of asesinato (murder).
2. Whether the penalty imposed, particularly the death penalty on the minor Binis, is correct.

RULING

1. Yes. The Supreme Court affirmed the conviction for asesinato. The killing was qualified by treachery (alevosía), as the victim was bound and defenseless when attacked. This brings the crime under Article 403 of the Penal Code. The crime was further aggravated by being committed at night and in a deserted place.
2. The penalty is affirmed for Alias and Castro but modified for Binis. The death penalty for Alias and Castro is affirmed as the maximum penalty for asesinato, with two aggravating circumstances and no mitigating circumstances. However, for Brigido Binis, who was found to be less than 18 years old at the time of the crime, the death penalty is improper under Article 85 of the Penal Code. Applying the rules for minors, he is sentenced to the maximum degree of the penalty immediately inferior to that for asesinato. Therefore, Binis is sentenced to 14 years, 8 months, and 1 day of cadena temporal, with accessory penalties and indemnity to the heirs.

DISPOSITION:
The death sentences for Isidoro Alias and Benito Castro are AFFIRMED. The sentence for Brigido Binis is MODIFIED to 14 years, 8 months, and 1 day of cadena temporal, with accessories and indemnity. Costs against appellants.