G.R. No. and Date: G.R. No. L-13177; March 12, 1918
Case Title: THE UNITED STATES, plaintiff-appellee, vs. FELINO CUNANAN, FERMIN BUCUD, PIO (POLICARPIO) BALATBAT, MARIANO BALATBAT and HILARIA SISON, defendants-appellants.

FACTS:
The defendants Felino Cunanan, Fermin Bucud, Pio (Policarpio) Balatbat, Mariano Balatbat, and Hilaria Sison were charged with the murder of Numeriano Regalado. The trial court convicted all defendants, sentencing Cunanan, Bucud, and Pio Balatbat to death, and Mariano Balatbat and Hilaria Sison to life imprisonment, with joint and several indemnity to the heirs of the deceased. The prosecution’s theory was that the defendants, armed with clubs, waited in a lonely place for Regalado and Hilaria Sison, killed Regalado, and threw his body into the river. The defense relied on alibi. Hilaria Sison was implicated either as having enticed the deceased to the location or as having illicit relations with him, during which the other defendants attacked and killed him.

ISSUE:
1. Whether the defendants are guilty of the crime charged.
2. Whether the aggravating circumstances of known premeditation and alevosia (treachery) are present.
3. Whether mitigating circumstances exist.

RULING:
1. As to Hilaria Sison: The Supreme Court acquitted her. Mere presence at the scene of the crime, without evidence of simultaneous cooperation, is insufficient to establish criminal liability as an accessory.
2. As to Felino Cunanan, Fermin Bucud, Pio Balatbat, and Mariano Balatbat: The Court found them guilty of homicide, not murder. The evidence, including eyewitness testimony and medical proof, established beyond reasonable doubt that they killed Regalado. However, the aggravating circumstances of known premeditation and alevosia were not sufficiently proven. The Court held that known premeditation requires proof of cold and deep meditation, not merely waiting in ambush. Alevosia was doubtful, but the aggravating circumstance of superior strength (more than three armed men attacking together) and committing the crime in an uninhabited place were present. No mitigating circumstances, such as vindication of a grave offense, were found for the Balatbats due to lack of proof.
3. Penalty: The four defendants were each sentenced to seventeen years, four months, and one day of reclusion temporal, with accessory penalties, and ordered to pay jointly and severally P1,000 to Regalado’s heirs. Costs were proportionately allocated.

Disposition: Hilaria Sison was acquitted. The convictions of the other four defendants were modified from murder to homicide, with corresponding penalties.

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