G.R. No. L-13312; April 1, 1918
THE UNITED STATES, plaintiff-appellee, vs. MAHARAJA ALIM, LAHAMAN, MUNAGIL, and SALATUNG, defendants.

FACTS:
In March 1917, in Daap, Zamboanga, the defendants were charged with the murder of the Moro Tantung. The information alleged that Maharaja Alim, an assistant chief of the settlement, conspired with and induced his co-accused Lahaman, Munagil, and Salatung (who were relatives of the deceased) to kill Tantung by offering them a reward of P100 and advancing P10. Acting on this inducement, on the night of March 16, 1917, Munagil, Lahaman, and Salatung went out to sea in a vinta, located Tantung who was fishing, and killed him using a lance and bolos. The killing was carried out with treachery, as Salatung asked Tantung for bait and, when Tantung extended his arm, Munagil and Lahaman stabbed him. Separate trials were held. Munagil and Lahaman pleaded guilty and were sentenced to death. After trial, Maharaja Alim and Salatung were found guilty of murder and sentenced to 20 years of reclusion temporal. They appealed.

ISSUE:
1. Whether the guilt of appellants Maharaja Alim and Salatung was proven beyond reasonable doubt based on the uncorroborated testimony of their accomplices.
2. Whether the qualifying and aggravating circumstances were correctly appreciated against each defendant.

RULING:
The Supreme Court affirmed the conviction of all four defendants for the crime of murder but modified the penalties.

1. On the Sufficiency of Evidence: The Court held that the uncorroborated testimony of accomplices Munagil and Lahaman, which was detailed and consistent, was sufficient to establish the guilt of Maharaja Alim and Salatung beyond reasonable doubt, following the doctrine in U.S. vs. Ocampo. Maharaja Alim did not present evidence to controvert the testimony. Salatung’s denial of participation was rejected as contrary to the logical sequence of events and his own admissions of being with the group before, during, and after the crime.

2. On Criminal Liability:
Maharaja Alim was liable as a principal by inducement. His offer of reward and assurance of protection were the direct and efficacious causes that persuaded the others, who had no motive of their own, to commit the crime.
Munagil and Lahaman were liable as principals by direct participation as the actual perpetrators.
Salatung was liable as a principal by direct participation. Although he did not inflict the fatal wounds, he conspired in the plot, carried the weapon, suggested the treacherous method, steered the boat, and performed acts integral to the execution of the crime.

3. On Qualifying and Aggravating Circumstances:
The crime was Murder, qualified by price/reward, which affected all defendants.
Aggravating Circumstances:
Premeditation and despoblado (commission at sea) affected all four defendants.
Nocturnity and treachery affected only Munagil, Lahaman, and Salatung, as these were not shown to have been induced by or known to Maharaja Alim.
Extenuating Circumstance: The minority and lack of instruction under Article 11 of the Penal Code (as amended) was considered but found insufficient to offset the multiple aggravating circumstances, given the defendants’ relative intelligence and the calculated acceptance of the reward.

4. On Penalty: The Court found the death penalty proper for all. However, due to the lack of unanimity required for its imposition under Act No. 2726, the penalty was reduced to cadena perpetua (life imprisonment) for each defendant.

DISPOSITIVE PORTION:
The judgment was modified. Each defendantMaharaja Alim, Munagil, Lahaman, and Salatungwas sentenced to the penalty of cadena perpetua. The judgment was affirmed in all other respects.