G.R. No. 26537, March 30, 1927
PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. LORENZO SANTOS, defendant-appellant.

FACTS

The case arose from the Constabulary riot in San Fernando, Pampanga, on May 23, 1926, which resulted in five deaths and eleven injuries. Accused Lorenzo Santos, a Constabulary soldier, was charged with the murder of 13-year-old Santiago Quiambao. The trial court, with the concurrence of two assessors, found Santos guilty based on the evidence. He was sentenced to *cadena perpetua* (life imprisonment), ordered to indemnify the heirs of the victim, and to pay costs. Santos appealed, challenging the credibility of witnesses and sufficiency of evidence.

The prosecution established that Santos was among the soldiers who armed themselves and participated in the riot. After leaving the dance hall where the trouble started, Santos headed toward the San Fernando railroad station. Near the station, a soldier (allegedly Santos) forced a store owner, Victorina Aguirre, to hand over money. Shortly thereafter, Aguirre’s son, Santiago Quiambao, was bayoneted to death by a Constabulary soldier. Later that night, Santos went to the house of Corporal Antonio Umali and confessed to Umali that he had killed a child near a store in front of the railroad station. During the investigation, Santos was among the soldiers who admitted participation, and his rifle was found missing two cartridges. However, forensic examination of his bayonet did not reveal bloodstains. Santos denied killing the boy.

ISSUE

Whether the trial court erred in convicting Lorenzo Santos of murder based on the evidence presented.

RULING

No, the trial court’s judgment is affirmed. The Supreme Court found no reversible error in the trial court’s findings.

The Court held that the testimony of Corporal Antonio Umali, corroborated by other witnesses, provided credible and sufficient evidence to establish Santos’s guilt. The defense’s challenge to Umali’s competency as a witness under Act No. 2709 was rejected, as the Court had previously given the statute a liberal interpretation allowing such testimony. The Court also reiterated its general rule of not disturbing the factual findings of the trial judge unless some material fact was overlooked or the conclusions were clearly erroneous. In this case, the trial court’s findings were supported by the evidence, including Santos’s own confession to Umali.

The killing was qualified by *alevosia* (treachery), as the attack on the young, unarmed victim was sudden and without risk to the assailant. No aggravating or mitigating circumstances were present. Therefore, the penalty of *cadena perpetua* for murder was appropriate.

*Judgment affirmed, with costs against the appellant.*