G.R. No. 31195 / July 27, 1929
PEOPLE OF THE PHILIPPINE ISLANDS vs. SULAMAN, SONTOT, ASLAL and TANDJILON

FACTS

The appellants, Sulaman, Sontot, Aslal, and Tandjilon, were convicted of murder by the Court of First Instance of Zamboanga for the killing of brothers Valente and Ananias de los Santos. They were sentenced to life imprisonment and ordered to indemnify the heirs of the deceased. The prosecution’s evidence included the testimony of Sacalol (a co-accused turned state witness), Santiago de los Santos (a companion of the victims), and Maulani (who saw one victim after the assault), as well as the appellants’ own affidavits admitting the killing. The appellants denied the charges at trial and presented witnesses to support an alibi.

ISSUE

Whether the trial court erred in convicting the appellants of murder.

RULING

No. The Supreme Court affirmed the conviction. The evidence overwhelmingly established the appellants’ guilt. Their denial and alibi were deemed inadequate and untrue. The crime was qualified as murder due to treachery (alevosía), as the victims were caught unprepared. The Court agreed with the finding of the aggravating circumstance of an uninhabited place but found evident premeditation not sufficiently proven. However, the penalty was not increased to its maximum degree, in line with the application of Section 106 of the Administrative Code of Mindanao and Sulu by the lower court. The appellants were thus sentenced to life imprisonment, the accessory penalties under Article 54 of the Penal Code, and ordered to jointly and severally indemnify the heirs of each victim in the amount of P1,000.