G.R. No. 1290 : January 5, 1905
THE UNITED STATES, complainant-appellee, vs. REGINO AYAO, ET AL., defendants-appellants.

FACTS:
On November 16, 1902, Pio Benedito, his wife Gregoria Miranda, their servant Faustina Bobiles, and Romualdo Espiritu were traveling to Narvacan. They stopped at Denden, where Benedito bathed. The defendant Regino Ayao joined them, pretending to look for a lost dog. While walking single file, Ayao, walking behind Benedito, suddenly attacked him with a bolo. After Benedito fled wounded, Ayao fetched his co-defendant Saturnino Bobiles, and together they killed Benedito. The eyewitnesses, Faustina Bobiles and Romualdo Espiritu, were threatened. Gregoria Miranda showed no alarm, later gave Ayao 15 pesos for killing her husband, and gave Espiritu 5 pesos for his silence. She then traveled back with Saturnino Bobiles and slept in the house of Antonio Banza, who was also involved. The defendants Regino Ayao and Antonio Banza confessed to the Constabulary inspector, corroborating the eyewitness accounts and leading to the discovery of the body. At trial, the defendants claimed their confessions were coerced and presented alibi defenses, which the court found unreliable.

ISSUE:
Whether the defendants are guilty of the crime of murder and what are the proper penalties to be imposed.

RULING:
The Supreme Court affirmed the guilt of the defendants but modified the penalties. The crime was murder, qualified by treachery (alevosia), as the attack was sudden and from behind, with the victim unaware. Regino Ayao and Saturnino Bobiles are principals by direct participation. Gregoria Miranda is a principal by inducement, having planned the crime and rewarded the perpetrators. The Court found the aggravating circumstance of an uninhabited place not sufficiently proven, thus giving the benefit of the doubt to the defendants. With no modifying circumstances, the penalty is imposed in its medium degree.

The Court sentenced Regino Ayao and Saturnino Bobiles to cadena perpetua. Gregoria Miranda, being a woman, was sentenced to reclusion perpetua under Article 95 of the Penal Code. All were ordered to jointly indemnify the heirs of the deceased with 500 pesos and pay costs. The crime is designated as murder, not parricide, as the complaint charged murder, and changing the qualification to the more serious crime of parricide would prejudice the defendant’s right to be informed of the charge.