G.R. L-No. 5154
THE UNITED STATES, plaintiff-appellee, vs. PEDRO SUPILA, defendant-appellant.
August 12, 1909

FACTS:
On the afternoon of May 11, 1907, Pedro Supila and three other armed individuals sequestered Fernando Medel and his wife, Francisca Gozon, from their home in Murcia, Occidental Negros. They led the couple into a sugar-cane field. Witnesses Pablo Flores and Basilio Escala heard the wife’s cries and attempted to intervene but were threatened by the armed men, including Supila, and prevented from entering the house. Flores begged for the woman’s release but was threatened. The following day, Medel’s body was found in the sugar-cane field with his elbows tied and several wounds, indicating he had been murdered. Francisca Gozon’s whereabouts remained unknown.

A complaint was filed against Supila and others. The provincial fiscal accused Materno Ocame as a principal and Pedro Supila as an accessory to the crime. The Court of First Instance acquitted Ocame and sentenced Supila, as an accessory, to twelve years and one day of cadena temporal, along with accessory penalties and P500 indemnity. Pedro Supila appealed, arguing he should only be considered an accomplice due to lack of evidence proving he inflicted the wounds.

ISSUE:
1. Whether the crime committed against Fernando Medel was murder.
2. Whether Pedro Supila’s participation amounted to that of an accessory, as charged by the fiscal and ruled by the trial court, or a co-author (principal) of the murder.
3. Whether a conviction for a higher degree of participation (co-author) is permissible when the complaint only accuses the defendant as an accessory, if the evidence supports the higher degree.

RULING:
1. The Supreme Court affirmed that the crime committed was murder, as Fernando Medel was deprived of his life while unarmed, tied, and unable to defend himself, demonstrating treachery on the part of the aggressors.
2. The Court found that Pedro Supila was a co-author (principal) of the murder. The evidence conclusively showed he was one of the four armed individuals who directly participated in the sequestration, binding, and transportation of Medel to the site of his murder, and actively prevented witnesses from intervening. The Court held that all those who took part in and witnessed the execution of the crime without opposing its consummation are equally responsible as co-authors.
3. The Court ruled that the mere fact that the complaint accused Supila as an accessory was not a bar to his conviction as a co-author, given that the evidence presented during trial unequivocally established his direct participation as a principal. The decision must be based on the evidence presented, not solely on the fiscal’s initial classification, especially when the facts alleged in the complaint already support the higher degree of participation.

Therefore, the Supreme Court reversed the trial court’s judgment, finding no aggravating or mitigating circumstances. Pedro Supila was sentenced, as co-author of the crime of murder, to cadena perpetua, to suffer accessory penalties, to indemnify the heirs of the deceased in the sum of P1,000, and to pay the costs of both instances.