G.R. No. 1502 : March 16, 1905
THE UNITED STATES, complainant-appellee, vs. BENJAMIN M. GOODWIN and FRANK CALDWELL, defendants-appellants.

FACTS:
The defendants, Benjamin M. Goodwin and Frank Caldwell, were charged with the crime of assassination for the killing of Toribio Taal on April 25, 1903, in Iligan, Misamis. Goodwin was Taal’s son-in-law. On the night of the incident, the defendants forcibly entered Taal’s house, engaged in a fight with him, beat him, and dragged him into the street. Approximately twenty yards from the house, Goodwin shot Taal in the chest with a revolver, causing his death within an hour or two. Goodwin claimed he acted in self-defense because Taal was about to attack him with a bolo, but no bolo was found at the scene, and witnesses did not see Taal armed. Caldwell participated in the fight and, immediately before the shooting, urged Goodwin to fire his revolver, saying, “Goodwin, fire the revolver at him,” and “You have not got any nerve if you don’t kill your papa.” The trial court convicted Goodwin as the principal and Caldwell as an accomplice, sentencing Goodwin to cadena perpetua and Caldwell to seventeen years and four months of cadena temporal.

ISSUE:
1. Whether the crime committed was assassination or homicide.
2. Whether the defendant Frank Caldwell should be considered a principal or merely an accomplice.

RULING:
The Supreme Court modified the trial court’s decision.
1. On the Nature of the Crime: The evidence did not establish the qualifying circumstances of premeditation or treachery (alevosía) necessary to classify the killing as assassination under Article 403 of the Penal Code. Therefore, the crime committed was homicide, punishable under Article 404.
2. On the Liability of Frank Caldwell: Under Article 13 of the Penal Code, a principal includes not only one who directly executes the act but also one who directly induces another to commit it. Caldwell’s acts of urging and inciting Goodwin to shoot the victim constituted direct inducement, making him a principal by induction, not merely an accomplice.
3. On Aggravating Circumstance: The defendants took advantage of their superior strength, an aggravating circumstance under Article 10(9) of the Penal Code.
4. Dispositive Portion: The sentence of the Court of First Instance was reversed. Both defendants were found guilty as principals of the crime of homicide. Considering the aggravating circumstance, the Supreme Court sentenced each defendant to eighteen years of reclusion temporal and to pay the costs of both instances.