People v. Dones
REITERATIONFacts
The Antecedents: In May 1901, Julian Dones was convicted of murder by a military commission in Sorsogon and sentenced to death. The sentence was approved, and an execution date was set. However, Dones escaped from prison and remained at large until his recapture in July 1902. By this time, the Civil Government had replaced the military government, and the commission that sentenced Dones had ceased to exist. Procedural History: In December 1905, the Attorney-General, acting on behalf of the Secretary of Finance and Justice, petitioned the Court of First Instance of Sorsogon to order the execution of Dones' death sentence. The court was asked to cite Dones to show cause why the sentence should not be carried out, pursuant to Acts Nos. 865 and 1153. After a hearing, the court ordered the execution of the sentence. Dones appealed this order to the Supreme Court. The Petition: Dones appealed the order of execution, raising two main arguments. First, he contended that the evidence presented by the Attorney-General in the lower court was insufficient to justify the order. Second, he challenged the constitutionality of Act No. 865 of the Philippine Commission, which authorized the execution of sentences rendered by military commissions. The Supreme Court addressed these points, noting that Dones admitted the underlying facts and that the constitutionality of Act No. 865 had already been upheld in a prior case.
Issue(s)
Whether the proof presented by the Attorney-General was sufficient to justify the order for the execution of the death sentence. Whether Act No. 865 of the Philippine Commission, authorizing the execution of sentences rendered by military commissions, is constitutional.
Ruling
The Supreme Court affirmed the order of the Court of First Instance directing the execution of the sentence. The costs of the instance were assessed against the appellant.
Ratio Decidendi
On the first issue (sufficiency of proof): The Court found that while the appellant questioned the probative value of the affidavit of the Executive Secretary and the uncertified translation of the military commission's proceedings, the appellant himself admitted the facts alleged by the Attorney-General in the Court of First Instance. The judge's order also noted the accused's admission of facts, stating that the accused admitted the facts but challenged the court's jurisdiction. Furthermore, the appellant's pleading opposing the sentence did not deny the facts but instead impugned the constitutionality of the relevant acts and the court's jurisdiction. This admission of facts by the accused obviated the need for the Attorney-General to present further proof and estopped the appellant from denying such facts. On the second issue (constitutionality of Act No. 865): The Court held that this issue had already been decided in the case of Narciso Cabantag vs. George N. Wolfe, wherein this Court declared Act No. 865 to be constitutional. Adhering to that prior decision, the Court found the appellant's claim regarding the unconstitutionality of the act to be unfounded. Therefore, the Court concluded that the lower court acted correctly in ordering the execution of the sentence.
Main Doctrine
The Supreme Court affirmed the order of the Court of First Instance directing the execution of a death sentence previously rendered by a military commission, holding that the execution of such sentences under Act No. 865 is constitutional and that the accused admitted the facts upon which the petition for execution was based.