GR 2012; (March, 1905) (Digest)
G.R. No. 2012 : March 17, 1905
THE UNITED STATES, complainant-appellee, vs. ENGRACIO ANGEL, ET AL., defendants-appellants.
FACTS:
On May 18, 1899, in Bacog, Malabon, Rizal, defendants Engracio Angel and Pablo Angel boarded a banca where Manuel Garcia, his wife Leonarda Geronimo, their 7-year-old daughter Rosa Garcia, and others were present. After binding the men, they demanded money from Leonarda. Despite receiving 14 pesos, they searched the boat and demanded more. When she could not produce more, they seized her and her child, threw them into the boat’s hold, and Engracio and Pablo hacked Leonarda to death with bolos, inflicting fatal wounds including severed hands. The child Rosa was later found alive but died fourteen days afterward. The third defendant, Saturnino Angel, remained on shore guarding a prisoner, Ruperto Oliveros, and shouting to prevent alarm, thereby aiding his co-defendants. The provincial fiscal charged all three with double murder.
ISSUE:
Whether the defendants are guilty of the crime of murder for the death of Leonarda Geronimo, and if so, what are their respective criminal liabilities and the proper penalty.
RULING:
The Supreme Court affirmed the conviction for murder but only for the death of Leonarda Geronimo. The Court held that:
1. Guilt for Murder: The killing of Leonarda Geronimo constituted murder qualified by treachery (alevosia). She was defenseless, of the weaker sex, and the sudden attack by armed men made self-defense or escape impossible.
2. Liability of All Defendants: All three defendants are liable as principals. Engracio and Pablo were direct perpetrators. Saturnino, by standing guard and preventing alarm, cooperated directly in the execution of the crime. The acts demonstrated prior conspiracy and common design.
3. Death of Rosa Garcia: The evidence was insufficient to prove that Rosa’s death fourteen days later was a direct result of the assault. Therefore, the charge of double murder was not sustained for her death.
4. Aggravating and Mitigating Circumstances: The aggravating circumstance of nocturnity attended the crime. However, this was offset by the mitigating circumstance under Article 11 of the Penal Code, considering the special conditions of disorder and resistance to authorities prevailing in the area at the time (May 1899). The penalty was thus imposed in its medium degree.
5. Penalty: The Court affirmed the trial court’s sentence of cadena perpetua (life imprisonment) with accessories. The defendants were also ordered to indemnify the heirs of Leonarda Geronimo jointly and severally in the amount of 1,000 pesos, and to pay the costs.