G.R. No. 33843 ; February 11, 1931
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. JUAN AGUINALDO, defendant-appellee.

FACTS

The accused, Juan Aguinaldo, was charged with murder for killing Anselmo Oao with a bolo on April 29, 1930, in Bacarra, Ilocos Norte. The information alleged the crime was committed in an uninhabited place with evident premeditation, treachery, and cruelty. The accused initially pleaded guilty before the justice of the peace but pleaded not guilty in the Court of First Instance. The trial court convicted him of murder, qualifying it with the circumstances of cruelty and uninhabited place, and sentenced him to life imprisonment. The evidence showed the accused attacked the victim from behind while the victim was stooping and digging roots, inflicting multiple fatal wounds. The accused testified he acted in self-defense, claiming the victim aggressively pursued him, but the court found this version not credible. He also claimed in a sworn statement that the victim’s wife instigated the crime, but he did not repeat this claim at trial.

ISSUE

Whether the trial court erred in convicting the accused of murder instead of homicide.

RULING

No, the trial court correctly convicted the accused of murder. The Supreme Court affirmed the conviction. The manner of attack—suddenly and from behind while the victim was bent down, unarmed, and unable to defend himself—constitutes treachery (alevosía), which qualifies the killing as murder under Article 403 of the Penal Code. The Court agreed with the Attorney-General that the aggravating circumstances of cruelty and uninhabited place were not sufficiently proven. The number of wounds alone does not establish cruelty without proof of deliberate intent to increase suffering, and there was insufficient evidence that the accused sought the solitude of the place to facilitate the crime. The penalty of life imprisonment, being the medium degree of the penalty for murder, was imposed in accordance with the law.

AI Generated by Armztrong.