G.R. No. L-5803 November 29, 1954
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NARCISO UMALI, ET AL., defendants. NARCISO UMALI, EPIFANIO PASUMBAL and ISIDRO CAPINO, defendants-appellants.

FACTS

Appellants Narciso Umali, Epifanio Pasumbal, and Isidro Capino were convicted by the Court of First Instance of Quezon for the complex crime of rebellion with multiple murder, frustrated murder, arson, and robbery, and each sentenced to life imprisonment with indemnities. The charges arose from a raid on the town of Tiaong, Quezon, on the evening of November 14, 1951, by armed men. The raid resulted in the burning of houses (including that of Mayor Marcial Punzalan, Valentin Robles, and one Mortega), the deaths of Patrolman Domingo Pisigan and civilians Vicente Soriano and Leocadio Untalan, the wounding of Patrolman Pedro Lacorte and five civilians, and looting of houses and Chinese stores. The political context involved a bitter rivalry between Congressman Narciso Umali and Mayor Marcial Punzalan, stemming from Umali’s jealousy over Punzalan’s popularity. During the 1951 election campaign, Umali supported Pasumbal against Punzalan. After Punzalan’s decisive victory, evidence showed that Umali and Pasumbal conspired with Huk Commander Abeng to kill Punzalan and stage the raid. Appellants were identified as participants: Umali was seen with armed men, Pasumbal was seen firing at Punzalan’s house, and Capino was recognized as one of the attackers. The raid was planned as a diversionary attack on an Army camp and a main assault on Punzalan’s house, but Punzalan was absent.

ISSUE

Whether the appellants are guilty of the complex crime of rebellion with multiple murder, frustrated murder, arson, and robbery, or of separate crimes.

RULING

The Supreme Court modified the lower court’s decision. It held that the appellants were not guilty of rebellion because the raid’s purpose was not to overthrow the government but to kill Mayor Punzalan for personal and political motives, constituting sedition. The crimes committed were sedition, multiple murder, arson, frustrated murder, and physical injuries. The murders were qualified by treachery and aggravating circumstance of abuse of superior strength, but due to lack of necessary votes, the penalty was reduced to life imprisonment. The Court sentenced each appellant to 5 years of prision correctional and a fine of P4,000 for sedition; life imprisonment and indemnity of P6,000 to the heirs of each victim for each of the three murders; and reclusion perpetua with indemnities for arson, applying Article 70 of the Revised Penal Code to limit the total duration of penalties to 40 years. The indemnities for frustrated murder and physical injuries awarded by the lower court were affirmed. The decision was affirmed with these modifications.