GR 958; (April, 1903) (Digest)
G.R. No. 958 : April 3, 1903
THE UNITED STATES, complainant-appellee, vs. JUAN BABASA, defendant-appellant.
FACTS:
On the night of January 27, 1899, the defendant-appellant, Juan Babasa, went to the house of Maria Antolin and called for her daughter, Fausta. Fausta, along with her mother and a young brother, came out. Upon reaching the door, Fausta was immediately stabbed in the abdomen by Babasa, from which wound she died the following day. The initial discovery by a police officer was met with the mother’s claim that the girl died of a stomach ache, but a medical examination revealed the fatal wound. The mother testified that Babasa had been making unwelcome advances towards her daughter prior to the incident. In his defense, Babasa claimed he was drunk and had no intention to harm, asserting that the family had agreed not to complain as they believed the stabbing was accidental. The defense also presented witnesses to establish the existence of amorous relations between the accused and the deceased.
ISSUE:
Whether the trial court correctly appreciated the aggravating and qualifying circumstances in convicting the accused of murder and imposing the death penalty.
RULING:
The Supreme Court modified the trial court’s decision. It held that the qualifying circumstance of treachery (alevosia) was present because the attack was sudden and unexpected, ensuring the victim’s defenselessness. However, the Court found no evidence to support the circumstance of premeditation. With treachery qualifying the crime as murder, the Court deemed it unnecessary to consider the aggravating circumstances of nocturnity, abuse of superiority, and dwelling, the latter not being sufficiently proven. As no other aggravating or mitigating circumstances attended the crime, the penalty must be imposed in its medium degree. Consequently, the Court sentenced Juan Babasa to life imprisonment (cadena perpetua), with the corresponding accessory penalties, ordered him to indemnify the heirs of the deceased in the amount of 1,000 Mexican pesos, and to pay the costs of both instances.