G.R. No. 29530 , December 8, 1928
PEOPLE OF THE PHILIPPINE ISLANDS vs. LAOTO, LABI, GUMAGADONG, MANINTONG NO. 1, MANINTONG NO. 2, UDTI and GUTI

FACTS

Otto Seifert, an American settler in Lanao, was killed by a group of armed Moros. The evidence established that prior to the killing, Seifert had disputes with several individuals, including appellant Sultan Laoto (over land ownership), B.F. Mabasa (over water rights), and Moro Karadang (over labor compensation). On the day of the crime, Seifert was shot dead on his boat. His servant, Aman, heard the shots and later defended Seifert’s house from an attack by a group of Moros, during which he killed one of the attackers, Andi (Laoto’s brother). Aman and Seifert’s wife identified some of the appellants among the attackers. After the crime, appellants Laoto and his men fled to the mountains and later surrendered with firearms, including a revolver belonging to Seifert. The trial court convicted all seven appellants of murder.

ISSUE

1. Whether the guilt of all appellants for the crime of murder was proven beyond a reasonable doubt.
2. Whether the aggravating circumstances were correctly appreciated.

RULING

The Supreme Court PARTIALLY GRANTED the appeal.

1. As to appellants Laoto, Manintong No. 1, and Guti: The Court ACQUITTED them. The evidence against them was insufficient to prove beyond reasonable doubt their direct or indirect participation in the crime. Laoto’s mere knowledge of the crime and his flight were not conclusive proof of conspiracy. Guti’s testimony that he was coerced into accompanying the group was not rebutted.

2. As to appellants Labi, Gumagadong, Manintong No. 2, and Udti: The Court AFFIRMED their conviction. The positive identification by witnesses Aman and Maxima Seifert, coupled with their collective armed action in attacking the house after the killing, proved their conspiracy with the principal killer, Karadang. As co-conspirators, they are equally liable for the murder.

3. On the Crime and Penalty: The crime committed is Murder. The Court agreed with the presence of the aggravating circumstances of evident premeditation and committed by a band (more than four armed persons). However, it disagreed with the lower court’s finding of the aggravating circumstance of uninhabited place, as the victim’s house was nearby. With two aggravating circumstances and no mitigating circumstances, the penalty should be imposed in its maximum degree (death). Nevertheless, pursuant to Section 106 of the Administrative Code of the Department of Mindanao and Sulu, which granted the trial court discretion to lower penalties, and finding no abuse thereof, the Supreme Court upheld the penalty of *life imprisonment* imposed by the trial court on the four convicted appellants.

DISPOSITIVE PORTION:
The judgment of the trial court is AFFIRMED with respect to appellants Labi, Gumagadong, Manintong No. 2, and Udti. It is REVERSED with respect to appellants Laoto, Manintong No. 1, and Guti, who are ACQUITTED on reasonable doubt.