GR 41358; (July, 1934) (Digest)
G.R. No. 41358; July 25, 1934
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. TOMAS LAYOS, defendant-appellant.
FACTS
The appellant, Tomas Layos, was convicted of the complex crime of double homicide for killing Andrea Paril and Bruna Caguyong. The prosecution’s eyewitnesses, Paula and Bonifacia Caguyong, testified that on September 22, 1933, while they were returning home, Layos attacked and hacked Bruna Caguyong to death. When Andrea Paril went to assist, Layos also attacked and killed her. Layos, in his sworn confessions, admitted to the killings, stating his motive was that Bruna had called him a lunatic. At trial, the defense challenged the credibility of the eyewitnesses and claimed Layos’s confessions were the result of brutal treatment. The defense also presented alibi witnesses.
ISSUE
1. Whether the trial court erred in finding Layos guilty of the killings based on the evidence.
2. Whether the confessions were admissible or were the result of brutal treatment.
3. Whether the trial court correctly appreciated the crime as double homicide.
RULING
The Supreme Court affirmed the conviction but modified the penalty. It held:
1. The trial court did not err in crediting the eyewitness testimonies of Paula and Bonifacia Caguyong, despite minor inconsistencies, as their accounts were convincing and consistent on material points. The appellant’s sworn confessions corroborated their testimony.
2. The claim that the confessions were extracted through brutal treatment was not substantiated by the evidence.
3. The trial court erred in treating the killings as a complex crime of double homicide. The killings constituted two distinct acts of homicide, not a single act. The proper penalty is two separate penalties for each homicide. Considering the mitigating circumstance of lack of instruction (illiteracy) and no aggravating circumstances, the Court modified the sentence to an indeterminate penalty of seven years of prision mayor to twelve years and one day of reclusion temporal for each death, and indemnity of P1,000 to the heirs of each victim.
AI Generated by Armztrong.