GR L 12057; (August, 1917) (Digest)
G.R. No. L-12057; August 30, 1917
THE UNITED STATES, plaintiff-appellee, vs. CLEMENTE GAMPOÑA, TOMAS MANGRUBANG and ROMAN GUILLERMO, defendants-appellants.
FACTS:
On or about April 1, 1915, in Sinait, Ilocos Sur, Leon Raneses was murdered. Clemente Gampoña, motivated by a desire to possess Raneses’s wife and property, induced Valentin Yacas, Liberto Tumbaga, Tomas Mangrubang, and Roman Guillermo to kill Raneses for a monetary reward. The conspirators lured Raneses to a remote, uninhabited mountain area under the pretense of finding a magical liquid called bulbulong. After Raneses fell asleep during the journey, the assassins attacked him: Yacas struck the fatal blow to the forehead with a hatchet, followed by Guillermo and Mangrubang striking his sides. The body was buried in a dry stream bed. The murderers were later paid P160 by Gampoña, which they divided among themselves. Only Gampoña, Mangrubang, and Guillermo were tried in this case, as Tumbaga was granted a severance and Yacas turned state witness after his confession.
ISSUE:
Whether the trial court correctly convicted the defendants of murder and imposed the death penalty, considering the presence of aggravating and mitigating circumstances.
RULING:
The Supreme Court affirmed the conviction and the imposition of the death penalty. The evidence, including the credible testimony of Valentin Yacas and corroborating confessions from the defendants, established their guilt beyond doubt. The crime was qualified as murder due to the presence of alevosia (treachery). Aggravating circumstances included craft, evident premeditation, commission in an uninhabited place, and reward. While nocturnity was absorbed in alevosia, and some aggravating circumstances overlapped, they were too numerous to reduce the penalty below the maximum. Ignorance and lack of education were considered mitigating for Mangrubang and Guillermo but insufficient to lower the penalty. Thus, the death penalty was proper under Article 403 of the Penal Code.
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