GR L 1312; (December, 1903) (Digest)
G.R. No. L-1312, December 21, 1903
THE UNITED STATES, complainant-appellee, vs. IGNACIO BUNDAL ET AL., defendants-appellants.
FACTS:
On the night of April 14, 1902, in Cagayancillo, Antique, a group of twenty-seven individuals conspired to kill Municipal President Marcos Buncag. The conspiracy was planned over several days in meetings convened by Ignacio Bundal. Pursuant to their plan, Bundal and Tomas Mamega went to Buncag’s house under the pretext of buying aniseed wine. When Buncag went to fetch the wine, Mamega suddenly attacked him with a bolo. As the wounded Buncag fled into the street, he was pursued and killed by other conspirators, including Santiago Madiong, who inflicted multiple fatal wounds. During the attack, Ignacio Bundal also attacked and mortally wounded the municipal secretary, Ciriaco Garrion, who died nine days later. After the killings, the conspirators controlled the town, exposed Buncag’s body in the municipal building, and intimidated the populace. They coerced Vice-President Francisco Magbanua and others, including the victim’s son, to sign a false report stating that the town had been attacked by unknown bandits. The accused were charged with the complex crime of double assassination.
ISSUE:
1. Whether the accused are guilty of the crime of double assassination.
2. Whether the amnesty proclaimed on July 4, 1902, is applicable to the accused.
RULING:
1. On the Guilt of the Accused: The Supreme Court affirmed the conviction of sixteen accused (Ignacio Bundal, Tomas Mamega, Procedio Bonales, Domingo Cardeño, Vicente Bombon, Gregorio Conde, Gregorio Elijan, Raymundo Cardeño, Gavino Condesa, Jacinto Bongar, Modesto Bundac, Ramon Condesa, and Juan Cardeño) for the complex crime of double assassination. The evidence clearly established a conspiracy and their direct participation in the killings of Marcos Buncag and Ciriaco Garrion. They were each sentenced to cadena perpetua (life imprisonment) with its accessory penalties and ordered to pay indemnity jointly and severally to the heirs of the deceased.
The Court acquitted Vice-President Francisco Magbanua, finding that he signed the false report under insuperable fear due to serious threats from the conspirators after the murders, thus negating criminal liability. Ten other defendants were also acquitted by the lower court, and as no appeal was taken, their acquittal became final.
2. On the Applicability of Amnesty: The Supreme Court held that the Amnesty Proclamation of July 4, 1902, did not apply to the sixteen convicted accused. The Court found that the crime was not political in nature but was a common crime arising from personal grievances and a conspiracy to murder a local official, not an act resulting from the internal political feuds or dissensions of the Philippine insurrections covered by the amnesty.
Dissenting Opinion: Justice McDonough dissented, arguing that the killing was political in motivean uprising to remove an oppressive officialand occurred during the period of the revolutions. He believed the accused should be granted amnesty under the terms of the proclamation.
