G.R. No. 9411 ; September 29, 1914
THE UNITED STATES, plaintiff-appellee, vs. ZACARIAS ESTOPIA, ET AL., defendants-appellants.

FACTS:
Defendants Zacarias Estopia, Dalmacio Daonoto, and Patricio Palgan were guests at a supper in the house of Benito Moso. Antonio Carreon, another guest, inadvertently stepped on Daonoto’s foot. Despite Carreon’s apology, Daonoto, aided by Estopia and Palgan, forcibly took Carreon to the lower part of the house. There, Daonoto held Carreon by the neck while Palgan raised his arms to prevent resistance. While Carreon was thus restrained, Estopia stabbed him in the abdomen with a dagger, causing his death the following day. The facts were established by the dying declaration of Carreon and corroborated by eyewitnesses. The trial court convicted all three of murder qualified by premeditation and treachery, with the generic aggravating circumstance of abuse of superior strength, and sentenced them to death.

ISSUE:
1. Whether the crime committed was murder or simple homicide.
2. Whether the qualifying circumstance of treachery (alevosia) was present.
3. Whether the aggravating circumstances of abuse of superior strength and commission with the aid of armed men or persons ensuring impunity were correctly applied.
4. Whether defendants Daonoto and Palgan are liable as co-principals.
5. The proper penalty to be imposed considering the defendants’ lack of education.

RULING:
The Supreme Court modified the trial court’s decision.
1. Classification of the Crime: The crime is murder, not simple homicide. The qualifying circumstance of treachery (alevosia) was present. The manner of attackwhere Carreon was suddenly seized and held by Daonoto and Palgan, rendering him defenseless before Estopia delivered the fatal stabensured the execution of the crime without risk to the assailants from any defense the victim might make. The Court held that premeditation did not exist as the quarrel arose unexpectedly.
2. Aggravating Circumstances: The Court ruled that the aggravating circumstance of abuse of superior strength was absorbed in treachery. The circumstance of commission “with the aid of armed men, or of persons who insure or afford impunity” was inapplicable.
3. Liability of Co-Defendants: Daonoto and Palgan are co-principals in the crime of murder. Their acts of seizing and restraining the victim constituted direct cooperation and were integral to the treacherous execution of the crime, making them equally liable with Estopia.
4. Penalty: The penalty for murder is cadena temporal in its maximum degree to death. Applying the Indeterminate Sentence Law and considering the mitigating circumstance of lack of education (under Article 11 of the Penal Code), the penalty was reduced to its minimum degree. The Court sentenced each defendant to twenty years of cadena temporal, with the corresponding accessory penalties.
5. Civil Liability: The defendants were ordered to jointly indemnify the family of the deceased in the amount of P1,000 and to pay the costs proportionately.

The judgment of the trial court was reversed accordingly.