G.R. No. L-8468; August 20, 1913
THE UNITED STATES, plaintiff-appellee, vs. LEONARDO BULFA, defendant-appellant.

FACTS

On the night of January 16 or early morning of January 17, 1912, in the barrio of Siapo, Oriental Negros, Leonardo Bulfa, accompanied by Benito Escamante and met by Apolonio Salasayo, set fire to the house of spouses Filomeno Catipay and Vicenta Salasayo. When Catipay attempted to climb to the roof to extinguish the fire, Bulfa thrust a lance through the wall, mortally wounding him. Bulfa then forced open the door, threatened Vicenta with a bolo, and compelled her to reveal where their money was hidden. He stole over P1,000. The house and its contents, worth about P500, were burned. Bulfa and Escamante fled and divided the stolen money. Vicenta Salasayo recognized Bulfa, a former resident of the barrio. The trial court convicted Bulfa of robbery with homicide and sentenced him to death.

ISSUE

Whether the trial court correctly convicted Leonardo Bulfa of the complex crime of robbery with homicide and imposed the penalty of death.

RULING

Yes. The Supreme Court affirmed the conviction. The facts constitute the complex crime of robbery with homicide under Article 503 of the Penal Code, as the killing was perpetrated to facilitate the robbery. The testimonies of eyewitnesses Vicenta Salasayo and Benito Escamante provided complete and convincing proof of Bulfa’s guilt as the principal perpetrator. The aggravating circumstances of treachery (No. 2), nighttime (No. 4), dwelling (No. 15), and by means of fire (No. 23) under Article 10 of the Penal Code attended the crime, with no mitigating circumstances to offset them. Applying the rules for indivisible penalties, the maximum penalty of death was properly imposed. The accessory penalties under Article 53 were also affirmed.