G.R. No. 1431 : January 27, 1904
THE UNITED STATES, complainant-appellee, vs. SIMON PUNSALAN, defendant-appellant.

FACTS:
On or about May 9, 1903, during a civil case before a justice of the peace in Candaba, Pampanga, the accused, Simon Punsalan, was the plaintiff and the deceased, Francisco P. Tizon, was the defendant. After the trial, while witnesses were signing their statements in the justice’s office, the justice invited Tizon to an adjoining room. As Tizon arose, Punsalan immediately followed him and stabbed him multiple times with a penknife, inflicting about fifteen wounds that caused Tizon’s death. The attack was sudden, and the deceased was unarmed. Punsalan was convicted of murder by the Court of First Instance of Pampanga and sentenced to cadena perpetua with accessories, indemnity, and costs.

ISSUE:
Whether the trial court correctly qualified the killing as murder and properly considered the aggravating circumstances.

RULING:
The Supreme Court affirmed the conviction for murder but modified the sentence regarding the aggravating circumstances. The killing was properly qualified by alevosia (treachery), as the attack was sudden and gave the victim no opportunity to defend himself. However, the Court found no evidence to support the aggravating circumstances of premeditation or that the crime was committed in a place where authorities were exercising their functions. With no aggravating or extenuating circumstances, the penalty was imposed in its medium degree under Article 97 of the Spanish Penal Code. The Court sentenced Simon Punsalan to cadena perpetua, with the accessories under Article 54(2) and (3), an indemnity of ₱2,000 to the heirs, subsidiary imprisonment in case of insolvency, and costs.