G.R. No. L‑5934
October 17 1910
United States v. Moro Labai

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Facts
– Moro Labai learned that his sweetheart, Salong, was to be married to Dangalug.
– In a fit of jealousy he consulted “Pintu” (Ricardo), who advised him to “break his rival’s head.”
– While Pintu was away Labai stole Pintu’s shotgun, went to the river, and found Salong seated in a vinta with her sister Saoda.
– Labai knelt on one knee, took aim and fired at close range (≈ 3 ft). The shot struck Salong (right side) and Saoda; Salong died within five hours.
– Two eye‑witnesses (Ungal and Saoda) saw Labai still holding the gun pointed at Salong after the discharge; they denied any struggle with a third person.
– The assistant fiscal charged Labai with murder under Art. 403, Penal Code. The Court of First Instance sentenced him to death by hanging, a ₱1,000 indemnity, and costs. The judgment was appealed.

Issue
1. Whether the facts constitute murder under Art. 403 (i.e., a lethal wound inflicted treacherously).
2. Whether the presence of aggravating (premeditation) and extenuating (customs of the race, lack of education, uncivilized condition) circumstances warrants the death penalty or a lesser penalty.
3. Whether the lower court erred in its conviction, the charge, or the prescribed penalty.

Ruling
– The Supreme Court held that the prosecution proved beyond doubt that Labai personally and directly caused Salong’s death with a shotgun fired at point‑blank range while the victim was unsuspecting, satisfying the elements of murder with treachery under Art. 403.
– The premeditation (consultation with Pintu, theft of the shotgun, purposeful search for the victim) constitutes an aggravating circumstance.
– The extenuating circumstance under Art. 11 (the defendant’s uncivilized customs, lack of education, and personal condition) balances the aggravating factor, nullifying any additional penalty that might arise from the use of an unlicensed firearm.
– Consequently, the death sentence is excessive. Applying the principle of compensation between aggravating and extenuating circumstances, the Court imposed the medium‑degree penalty for murder: life imprisonment, accessory penalties Nos. 2 and 3 of Art. 54, ₱1,000 indemnity to the heirs, and costs of both instances.
– The judgment of the Court of First Instance was reversed insofar as the death penalty; the conviction for murder was affirmed.

Disposition: Reversal of the death‑penalty judgment; sentencing Labai to life imprisonment, accessory penalties, indemnity, and costs.

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Concurred by: Arellano C.J., Johnson, Moreland, and Trent JJ.