G.R. No. L-3772 May 13, 1953
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MAUTI LINGCUAN and MAMANTUK MAUTI, defendants-appellants.

FACTS

On the evening of March 31, 1949, Gadungan Mantar was shot in her home in barrio Madaya, Dansalan, Lanao, and died three days later. Two family members, Tiburon Mantar and Macapanton Macadaag, testified they saw and identified the appellants, Mauti Lingcuan and Mamantuk Mauti (father and son), along with Lomangcolob Dimaocom (at large), as the assailants fleeing the scene with firearms. The prosecution presented circumstantial evidence from Moslem Ayo, who testified that earlier that day, Mauti Lingcuan, being a district mayor and feeling ashamed due to a criminal complaint for estafa filed against him by Namir Mantar (the deceased’s father), threatened to kill Namir Mantar or his family if Ayo did not pay a debt. Another witness, Pangandaman Dimapunong, testified that on the night of the shooting, he saw and recognized the two appellants and Lomangcolob running near a bridge, carrying firearms, and heard Lingcuan tell Mamantuk to hurry. The defense relied on alibi. It was admitted that Mauti Lingcuan had a pending estafa case filed by Namir Mantar, which was a source of resentment. Mamantuk Mauti was 15 years old at the time of the crime.

ISSUE

The primary issue is whether the guilt of the appellants for the crime of murder was proven beyond reasonable doubt based on the evidence presented, particularly the credibility of the prosecution’s witnesses and the circumstantial evidence. A subsidiary issue concerns the proper penalty for the minor appellant, Mamantuk Mauti.

RULING

The Supreme Court affirmed the conviction but modified the penalty for Mamantuk Mauti. The Court found the testimonies of Moslem Ayo and Pangandaman Dimapunong credible and sufficient to establish guilt beyond reasonable doubt. Their testimonies were corroborated by the motive stemming from the estafa case and Lomangcolob’s flight after the case’s temporary dismissal, which implicated all three assailants. The Court expressed doubt about the ability of Tiburon Mantar and Macapanton Macadaag to positively identify the assailants under the circumstances but held the other evidence was conclusive. Regarding Mamantuk Mauti, who was 15 at the time of the crime but over 18 by the time of the trial, the Court ruled he was no longer entitled to the benefits of Article 80 of the Revised Penal Code (suspension of sentence and commitment to an institution). Applying Article 68(2), the penalty next lower than that prescribed by law was imposed. The decision was modified: Mauti Lingcuan’s penalty of reclusion perpetua was affirmed; Mamantuk Mauti was sentenced to an indeterminate penalty of 6 years of prision mayor to 14 years, 10 months, and 20 days of reclusion temporal; and the indemnity to the heirs was increased to P6,000, jointly and severally payable by both appellants.