G.R. No. 55 : March 19, 1902
THE UNITED STATES, complainant-appellee, vs. MARIANO RICAFOR, defendant-appellant.

FACTS:
On a night in March 1900, the defendant, Mariano Ricafor, together with Gabino Marquez and accompanied by Clemente Oli, Marcos Nares, and Cornelio Tabajonda, went to the house of Pedro Lorioda in Pozorrubio, Pangasinan. The Lorioda brothers, Pedro and Juan, were taken from their house. The group, led by the defendant and Marquez, then conducted the victims to a field where there was a well. At that location, the defendant and Marquez bound the victims and killed them by inflicting bolo wounds to the neckthe defendant killing Pedro, and Marquez killing Juan. The bodies were thrown into the well. The eyewitness accounts of the abduction from the house were provided by Oli, Nares, Tabajonda, and the wife and daughter of Pedro Lorioda. The details of the killing were testified to by Oli, Nares, and Tabajonda, who were deemed accomplices but whose testimonies were largely corroborated. The Court of First Instance of Pangasinan convicted the defendant of assassination without any qualifying circumstance and sentenced him to life imprisonment.

ISSUE:
Whether the trial court correctly convicted the defendant of the crime of assassination, and if so, whether the qualifying circumstance of treachery and the aggravating circumstance of evident premeditation were present.

RULING:
The Supreme Court reversed the judgment of the trial court. It found that the crime committed was assassination, qualified by the circumstance of treachery (alevosía). The act of binding the victims, which rendered them incapable of defense, was done to ensure the execution of the crime without risk to the assailants, constituting treachery. Furthermore, a majority of the Court held that the aggravating circumstance of evident premeditation was present. The series of actsthe deceit to gain possession of the victims, their abduction, their conveyance to a secluded location chosen for concealing the bodies, and their bindingdemonstrated a deliberate and reflective plan conceived at least from the moment of the abduction. No extenuating circumstances were found to offset this aggravation. The Court rejected applying the extenuating circumstance of race under Article 11 of the Penal Code, considering the nature of the crime and the conditions of the defendant. Consequently, the penalty was elevated to death. The defendant was also ordered to pay an indemnity of 1,000 Mexican pesos to the heirs of Pedro Lorioda. The case was remanded to the trial court for execution of the sentence.