G.R. No. L-11510; August 8, 1916

FACTS:
The defendants-appellants, Bahatan and Kamihan, both Igorrotes, were charged with the crime of murder. They pleaded guilty upon arraignment and voluntarily testified, detailing the reasons and manner in which they killed the victim, Lajo. The trial court found them guilty of murder with the aggravating circumstances of premeditation and despoblado (committed in an uninhabited place) and sentenced them to death. The case was elevated to the Supreme Court en consulta (automatically) due to the imposition of the death penalty.

ISSUE:
1. Whether the aggravating circumstances of despoblado and premeditation were sufficiently proven.
2. Whether Article 11 of the Penal Code, which provides for a mitigating circumstance for those who act without full consciousness of the wrongfulness of their act due to lack of education or cultural background, should be applied in favor of the accused.

RULING:
The Supreme Court modified the judgment of the trial court.
1. On the aggravating circumstances: The Court found the evidence insufficient to prove despoblado, as the killing occurred only about 150 meters from a house owned and occupied by Bahatan. The Court also ruled that premeditation was not present, as the conception of the crime was substantially simultaneous with its execution. The idea to kill Lajo as revenge for the death of Bahatan’s grandfather originated from another Igorrote by suggestion and was not a product of sustained reflection by Bahatan.
2. On the application of Article 11: The Court held that the trial court erred in not applying Article 11 of the Penal Code. The appellants, being members of a pagan savage tribe (Igorrotes), were ignorant of the laws and customs of civilized society. They were brought up under tribal beliefs that justified killing under the circumstances of this case, thereby acting without full consciousness of the wrongfulness of their act.
3. Classification of the crime: The Court agreed with the trial court that the crime constituted murder, qualified by alevosia (treachery), as demonstrated by the accused’s own account of the killing.

DISPOSITIVE PORTION:
The death sentence was set aside. The accused were each sentenced to 17 years, 4 months, and 1 day of cadena temporal (reclusion temporal), to indemnify jointly and severally the heirs of the deceased Lajo in the sum of P1,000, and to pay the costs of the trial. No costs were awarded for the appeal.