G.R. No. L-26361, January 20, 1927
PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. CRISPINO MANCAO and CIRIACO AGUILAR, defendants-appellants.

DOCTRINE:
1. Conspiracy and Liability for Acts of Cohorts: A person who instigates an aggression and calls others to his aid is liable not only for his own acts but also for the acts of those who aided him in carrying out the criminal act he started.
2. Defense of Mental Deficiency: The defense of mental deficiency (e.g., epilepsy) to negate criminal liability requires proof that the accused was under the influence of such a condition at the time of the commission of the crime, depriving him of his mental faculties.

FACTS

Crispino Mancao was the court-appointed administrator of the intestate estate of Hilaria Dejan. Roberto Villela, a lessee, refused to surrender possession of some lands belonging to the estate. The court had cited Mancao to explain why these lands were not in the estate’s inventory and ordered him to take steps to obtain possession.

On August 10, 1925, Mancao, accompanied by several persons including Ciriaco Aguilar, went to harvest corn from the disputed land leased by Villela. Upon being notified, Villela confronted the harvesters. When Villela asked Mancao if he had a court order to harvest, Mancao struck him with a bamboo stick, saying, “This is the order.” A fight ensued. Mancao, armed with a bolo, inflicted slight wounds on Villela. Seeing he was getting the worst of the hand-to-hand struggle, Mancao shouted for help. Several of his companions intervened, striking Villela. While Mancao held Villela, Ciriaco Aguilar struck Villela in the back with a sickle, inflicting a deep wound that nearly severed his spine. Villela died from his wounds on August 26, 1925.

The prosecution’s version, supported by eyewitnesses, was that Mancao was the aggressor. The defense claimed Villela attacked first with a bolo, and Mancao acted in self-defense. They also claimed Aguilar, an epileptic, was not criminally liable due to mental deficiency.

The trial court convicted both appellants of homicide.

ISSUE

1. Whether the trial court erred in giving credence to the testimony of the prosecution’s young witnesses.
2. Whether the evidence for the defense preponderates over that of the prosecution.
3. Whether the accused are entitled to the benefit of reasonable doubt.
4. Whether accused Ciriaco Aguilar is mentally deficient and therefore not criminally liable.
5. Whether the trial court erred in convicting the accused instead of acquitting them.

RULING

The Supreme Court AFFIRMED the judgment of the trial court.

1. On the Credibility of Witnesses: The Supreme Court found no error in the trial court’s assessment. The age of the witnesses (15 and 14) did not automatically discredit their testimony, especially since their account was consistent and supported by other evidence.

2. & 3. On the Weight of Evidence and Reasonable Doubt: The evidence for the prosecution was found to be stronger and more credible. Mancao’s claim of self-defense was untenable. The circumstances showed he was the aggressor: he went to the land knowing Villela would object, he was armed, and he initiated the violence when questioned. His act of calling for help during the fight indicated he sought aid to overcome Villela, not to defend himself. No reasonable doubt existed as to their guilt.

4. On the Mental Deficiency of Ciriaco Aguilar: The defense failed to prove that Aguilar was suffering from an epileptic fit at the time of the crime. While an epileptic may have moments of unconsciousness, there was no evidence he was in such a state before, during, or immediately after the aggression. Therefore, the defense of lack of free will or mental deficiency could not be sustained.

5. On Criminal Liability:
* Ciriaco Aguilar was liable as a principal for having directly participated by inflicting the fatal wound.
* Crispino Mancao was also liable as a principal. As the instigator and initial aggressor who called his companions to his aid, he was criminally responsible not only for his own acts but also for the acts of his cohorts (including Aguilar) in carrying out the criminal act he started.

The Supreme Court held both appellants guilty beyond reasonable doubt of the crime of homicide.