GR 2186; (May, 1905) (Digest)
G.R. No. 2186
Date: May 5, 1905
Parties:
– Complainant-Appellee: The United States
– Defendants-Appellants: Lorenzo Balisacan, et al. (including Ambrosio Agnis, Eulogio Malvar, Zoilo Malvar, Santos Manuel, Mariano Ganutisi, and Pedro Ganiron, among others)
FACTS:
The defendants were charged with the killing of Antolin Alejandro. The evidence showed that a group of defendants took Antolin Alejandro from his house and later killed him. Appellants Ambrosio Agnis, Eulogio Malvar, and Zoilo Malvar were present from the time the deceased was taken until his death. Defendants Santos Manuel and Mariano Ganutisi did not go to the exact location of the killing but were assigned to guard the witness Mateo Reyes at a distance from the crime scene.
Pedro Ganiron was also convicted in the lower court, though the Solicitor-General argued the evidence was insufficient. The witness Mateo Reyes initially stated Pedro Ganiron was present and participated but quickly recanted, claiming Ganiron was not present. However, six other defendants testified that Ganiron was the moving spirit behind the crime, motivated by a belief that the deceased and Mateo Reyes had stolen his property. Mateo Reyes corroborated parts of this by admitting Ganiron had filed a theft complaint against him and the deceased and by confirming details about Ambrosio Agnis’s uniform.
ISSUE:
1. Whether appellants Ambrosio Agnis, Eulogio Malvar, and Zoilo Malvar should be held liable as principals for the killing of Antolin Alejandro.
2. Whether defendants Santos Manuel and Mariano Ganutisi should be considered principals despite not being at the exact location of the killing.
3. Whether the conviction of Pedro Ganiron was supported by sufficient evidence, given the conflicting testimony.
RULING:
1. As to Ambrosio Agnis, Eulogio Malvar, and Zoilo Malvar: The Supreme Court held that their presence and participation from the abduction to the killing made them principals in the crime. Their claim of taking no actual part was rejected.
2. As to Santos Manuel and Mariano Ganutisi: The majority of the Court held that by guarding the witness Mateo Reyes to prevent interference, they cooperated in the execution of the crime and were thus also principals.
3. As to Pedro Ganiron: The Court affirmed his conviction. While the Solicitor-General argued that a defendant should not be convicted solely on the testimony of co-defendants, the Court found sufficient corroboration. Mateo Reyes’s testimony about the theft complaint and uniform details, along with his initial statement implicating Ganiron, supported the co-defendants’ accounts. The evidence established Ganiron’s involvement as the instigator.
The judgment of the lower court was affirmed in its entirety, with costs against the appellants.
Concurring Justices: Arellano, C.J., Torres, Mapa, Johnson, and Carson.
