GR 2126; (September, 1905) (Digest)
March 6, 2026GR 2288; (September, 1905) (Digest)
March 6, 2026G.R. No. 2275
Date: September 21, 1905
Parties:
– Plaintiff-Appellee: The United States
– Defendant-Appellant: Ignacio Dalasay
FACTS:
The defendant, Ignacio Dalasay, was charged with the crime of assassination for killing Graciano Anacajan on a night in July 1904 in the barrio of Quios, Panitan, Capiz. The information alleged that Dalasay, without motive, inflicted multiple bolo wounds on Anacajan, causing his death. During the trial in the Court of First Instance of Capiz, the evidence showed that on the afternoon of the incident, both Dalasay and the deceased had been drinking tuba together and became intoxicated. Later, the deceased demanded more tuba from Dalasay’s wife, leading to an altercation. The deceased threatened to burn Dalasay’s house, and subsequently, Dalasay’s house and another nearby house were burned, though it was not conclusively proven that the deceased set the fire. Dalasay admitted to killing Anacajan but raised the defense of unlawful aggression by the deceased. The trial court convicted Dalasay of homicidio (homicide) instead of assassination, sentencing him to twelve years and one day of reclusión temporal, with accessories, and ordering him to pay indemnity to the heirs of the deceased. The court considered his drunkenness at the time of the crime as an extenuating circumstance, noting he was not a habitual drunkard. No aggravating circumstances were found.
ISSUE:
Whether the trial court correctly convicted the defendant of homicide and properly applied the extenuating circumstance of drunkenness.
RULING:
The Supreme Court affirmed the judgment of the trial court. The evidence presented during the trial was sufficient to support the conviction for homicide. The Court agreed with the trial court’s consideration of the defendant’s drunkenness as an extenuating circumstance under Article 9 of the Penal Code, as the defendant was not an habitual drunkard and his intoxication was not habitual. No aggravating circumstances attended the commission of the crime. The penalty imposed by the lower court was deemed appropriate and in accordance with the law. The decision was affirmed in its entirety.
Concurring Justices: Arellano, C.J., Torres, Mapa, Carson, and Willard.