G.R. No. 3255 THE UNITED STATES vs. CANDIDO ULAT

FACTS:
The prosecution charged Constabulary soldier Candido Ulat with murder for killing his concubine, Basilia Casili, on the night of 8 January 1906 in a deserted area of Calapan, Mindoro. The victim was seven months pregnant. Ulat’s commanding officer had warned him to cease the illicit liaison and, upon learning of the pregnancy, threatened legal action unless Ulat married the woman. Ulat denied paternity but reluctantly promised to marry her after the child’s birth while simultaneously courting another woman. On 9 January 1906 the body was found; autopsy showed multiple fatal blows from a clubbed rifle and a broken trigger screw, which the constabulary’s rifle inspector linked to the weapon’s use as a bludgeon. Ulat was seen leaving his post at midnight, absent for about two hours, and returning from the vicinity where the body was later discovered. No defense witnesses were presented.

ISSUE:
Whether the evidence proved, beyond reasonable doubt, the qualifying circumstance of treachery (and, alternatively, pre‑meditation and vindictiveness) required to sustain a conviction for murder, or whether the proper conviction should be for homicide.

RULING:
The Supreme Court held that the prosecution failed to establish treachery, pre‑meditation, or vindictiveness with the certainty required for a murder conviction. No eyewitness testified to the manner of the attack, and the nature of the wounds did not demonstrate the presence of treachery as defined by Art. 10 of the Penal Code. Consequently, the conviction for murder was set aside. The Court affirmed liability for homicide, an aggravating circumstance being the commission of the crime in a deserted place, and imposed the maximum penalty of reclusion temporal (twenty years), accessory penalties under Art. 59 of the Penal Code, payment of ₱1,000 to the heirs of the deceased, and costs of proceedings. The judgment of the trial court was reversed and remitted for execution of the revised sentence.