G.R. No. L-981 : October 8, 1903
THE UNITED STATES, complainant-appellee, vs. EMILIANO CAJAYON, ET AL., defendants-appellants.

FACTS:
On the night of March 21, 1901, in Lubang, Cavite, a group of about twelve armed men assaulted the house of Doña Ana Muriel. They robbed the house of jewelry, clothing, documents, and cash. The assailants then seized Tranquilino Torres, who lived in the house, bound him elbow to elbow, and took him away. He was brought to the barrio of Maliig, near the house of Pedro Villaflores, where he was killed and buried. Five or six days later, placards posted around the town led authorities and the victim’s son to the location. There, they found scattered human remains, clothing, a hat, and a piece of rope. The remains and belongings were identified as those of Tranquilino Torres. The accusedEmiliano Cajayon, Felix Aguilar, Domingo Castillo, Quintin de Lemos, Tomas Ramirez, Pioquinto Cajayon, Gregorio Tria, Candido Aguilar, and Mariano Aguilarwere charged with murder based on these events.

ISSUE:
Whether the accused are guilty of the crime of murder.

RULING:
Yes. The Supreme Court affirmed the conviction for murder. The facts established that the killing of Tranquilino Torres was attended by the qualifying circumstance of alevosia (treachery). The victim was bound and helpless, unable to defend himself from his armed assailants, ensuring the execution of the crime without risk to the perpetrators. The evidence, including eyewitness testimonies from neighbors who identified several of the accused during the robbery and kidnapping, and circumstantial evidence leading to the discovery and identification of the victim’s remains, proved the guilt of the appellants beyond reasonable doubt.

The Court sentenced each of the nine convicted defendants to cadena perpetua (life imprisonment), with the corresponding accessory penalties, and ordered them to pay, jointly and severally, an indemnity of 1,000 pesos to the heirs of the deceased.

Dissenting Opinion:
Justice Cooper, joined by Justice McDonough, dissented. They argued that the complaint was fatally defective as it failed to allege directly that the defendants killed the deceased or that the killing was committed with alevosia or premeditation, which are essential to constitute murder. The dissent contended that the complaint only alleged seizure and carrying away of the deceased, and the subsequent discovery of his body, which is insufficient to charge murder. Furthermore, they noted that the Supreme Court’s sentence imposed a higher penalty (life imprisonment) than the trial court’s sentence (12 years for most defendants), depriving them of an opportunity to challenge the defective complaint regarding the increased penalty.