G.R. No. 1758 : March 13, 1905
THE UNITED STATES, complainant-appellee, vs. MACARIO CATIGBAC, defendant-appellant.

FACTS:
The defendant, Macario Catigbac, was charged with the crime of assassination. The complaint alleged that on the evening of September 12, 1903, in Lipa, Batangas, the accused, after lying in wait for Ireneo Abaca, called to him under the pretext of wishing to speak and then inflicted mortal wounds with a poniard, from which Abaca died early the next morning. The evidence at trial revealed that the deceased owed the defendant a sum of money. The accused had gone to the deceased’s house that afternoon to collect the debt, which the deceased had promised to pay that day, but the deceased was absent. Later that same day, the accused searched for and eventually met the deceased on a street. A quarrel over the debt ensued, which escalated into a fight. During the fight, the accused wounded the deceased with a poniard, causing his death several hours later. Immediately after the incident, the accused presented himself and the weapon to the provincial governor.

ISSUE:
Whether the crime committed by the accused constitutes assassination or the lesser crime of homicide.

RULING:
The Supreme Court ruled that the crime committed was homicide, not assassination. The evidence failed to establish the qualifying circumstances of premeditation or alevosia (treachery) necessary to qualify the killing as assassination. The fight arose from a sudden quarrel over a debt, and there was no showing that the accused employed means to ensure the execution of the crime without risk to himself. Since no aggravating or extenuating circumstances attended the commission of the crime, it is properly classified as simple homicide under Article 404 of the Penal Code. Accordingly, the Court reversed the death penalty imposed by the trial court and sentenced the defendant to seventeen years and four months of reclusion temporal, with costs.