People v. Feria
REITERATIONFacts
The Antecedents: On November 12, 1901, Evaristo Perez, a municipal policeman, was carrying an official letter from San Isidro to Jaen. While passing through Cabalantian, he was accosted by Juan Feria and Dionisio Velasquez. Feria seized Perez, while Velasquez attempted to seize Valentin Ramos, a young companion of Perez, who managed to escape. Velasquez then returned and, with Feria holding Perez, inflicted multiple mortal wounds on Perez with a bolo and a dagger. The assailants then took Perez's Colt revolver, belt, and sheath. Procedural History: The incident was reported by Ramos to the municipal police. Upon investigation, Perez was found mortally wounded and died en route to town. The municipal physician examined the body and detailed the severe wounds. The complaint charged the accused with murder. The Appeal: Juan Feria and Dionisio Velasquez pleaded not guilty. They testified that they acted under the orders of three other men and that these men killed the policeman. This testimony contradicted their earlier confessions made before the justice of the peace of Jaen, where they admitted their participation, though differing on who inflicted the fatal blows. The prosecution's case was corroborated by the eyewitness, Valentin Ramos, who identified the accused and described their actions. The revolver taken from Perez was later found in the possession of Francisco Donato, who received it from Velasquez. The trial court found the defendants guilty of murder. The defendants appealed this judgment.
Issue(s)
Whether the accused, Juan Feria and Dionisio Velasquez, are guilty of murder as charged. Whether treachery was present as a qualifying circumstance.
Ruling
The Supreme Court affirmed the guilt of Juan Feria and Dionisio Velasquez for the murder of Evaristo Perez. The Court ruled that treachery was present, qualifying the crime as murder. The judgment of the lower court was reversed in part, with the penalty of life imprisonment (cadena perpetua) imposed on each defendant. They were also ordered to pay jointly and severally an indemnity of 2,000 Mexican pesos to the heirs of the deceased and to pay one-half of the costs of the instance.
Ratio Decidendi
On Issue 1: The guilt of Juan Feria and Dionisio Velasquez as principals by direct participation in the murder of Evaristo Perez is unquestionable. Their guilt is established not only by their confession in the justice's court of Jaen, which was made in the presence of seven witnesses, but also by the corroborating testimony of the eyewitness, Valentin Ramos. The accused's subsequent statements at the trial, claiming they acted under orders from other men, were unsupported by evidence and contradicted their prior confessions. The Court found no evidence of coercion or the existence of the other men mentioned by the accused. Furthermore, their own testimonies at the trial plainly demonstrated their direct participation in the violent and treacherous killing of the policeman. On Issue 2: Treachery (alevosia) was present as a qualifying circumstance. The policeman, Evaristo Perez, was attacked by one of the defendants while being held by the other, preventing him from defending himself or escaping. This method of attack directly and specially tended to insure the consummation of their criminal purpose without risk to themselves. The fact that Perez was armed with a revolver does not negate treachery, as the record does not show he was able to use it; on the contrary, the suddenness of the attack prevented any defense or escape from the beginning. The Court found no generic aggravating or extenuating circumstances, thus treachery was the sole circumstance determining the classification and legal character of the crime as murder.
Main Doctrine
The crime of murder is committed when treachery is present, meaning the offender employs means, methods, or forms in the execution of the crime which tend directly and specially to insure its execution without any risk to himself arising from the defense which the offended party might make. In this case, the victim was held by one assailant while the other inflicted mortal wounds, thus ensuring the commission of the crime without risk to the assailants and establishing treachery.