People v. Maquiraya
REITERATIONFacts
The Antecedents: Agents of the Internal Revenue Service, A. C. Wright and Damian Magudatu, were investigating a clandestine distillery in the Province of Cagayan. They discovered the distillery operated by several individuals, including the accused Vicente Maquiraya and Jose Acquebay, who were identified by an associate, Jorge Mañgabilin. The accused agreed to help the agents remove the distillery's effects. While Wright was taking notes inside the distillery, Maquiraya attacked him with a bolo, inflicting a severe wound that destroyed his left eye and cut his jawbone. Maquiraya also wounded Magudatu. Wright, despite his injuries, fired his revolver, causing the accused and others to flee. Procedural History: The defendants were charged with frustrated assassination (asesinato frustrado). The Court of First Instance of Cagayan convicted Vicente Maquiraya and Jose Acquebay, sentencing Maquiraya to fourteen years, eight months, and one day of cadena temporal, and Acquebay to eight years and one day of presidio mayor. Both were ordered to pay costs. The Petition: The defendants appealed the judgment and sentence to the Supreme Court, raising two main claims: (1) that Fernando Ballatin, not Maquiraya, delivered the blow to Wright, and (2) that there was no proof of premeditation.
Issue(s)
Whether the evidence clearly established that Vicente Maquiraya inflicted the wound upon A. C. Wright. Whether there was sufficient proof of premeditation to establish the crime of frustrated assassination. Whether Jose Acquebay was guilty of frustrated assassination based on the evidence presented. Whether the aggravating circumstances of alevosia and despoblado should have been considered in sentencing Maquiraya.
Ruling
The Supreme Court affirmed the conviction of Vicente Maquiraya but modified the sentence, imposing a penalty of seventeen years and four months of cadena temporal, with accessories, and ordered the acquittal of Jose Acquebay. The Court reserved Mr. Wright's right to maintain a civil action for damages.
Ratio Decidendi
On whether Vicente Maquiraya inflicted the wound: The Court found the evidence clear that Vicente Maquiraya assaulted Wright. Wright himself identified Maquiraya at the time of the blow. This testimony was corroborated by Damian Maggudatu, Wright's assistant, and Fernando Ballatin. The defense's claim that Fernando Ballatin delivered the blow was dismissed due to the clear and corroborated eyewitness accounts. On the proof of premeditation: The Court found sufficient proof of premeditation. Fernando Ballatin testified that Maquiraya invited him and others to kill Wright and his companion. While accomplice testimony requires caution, it was corroborated by circumstances: the accused were armed and facing certain conviction for a long prison term; they were observed in secret conversations that ceased upon Wright's approach; Maquiraya urged his companions to join the attack, stating, "What are you doing? Come on and let us kill all of them."; and all the accused fled when Wright fired his revolver. These facts established a conspiracy and intent to kill. On the guilt of Jose Acquebay: The Court found the evidence against Jose Acquebay insufficient for conviction. At the time of the assault on Wright, Acquebay was outside the distillery, occupied with removing jars. Fernando Ballatin's testimony indicated Acquebay did not assist in the assault, nor did he appear to have participated in the agreement to kill Wright. Therefore, under the Court's holdings, the evidence did not sustain his conviction. On the aggravating circumstances: The Court held that the trial court erred in not sufficiently considering the aggravating circumstances of alevosia (treachery) and despoblado (uninhabited place). Mr. Wright testified that the distillery was in a sparsely settled district, at least a mile from any habitation, and the clandestine nature of the distillery further indicated an uninhabited location. The Court concluded that these circumstances warranted the imposition of the maximum penalty upon Maquiraya.
Main Doctrine
The Supreme Court modified the conviction of Vicente Maquiraya for frustrated assassination, increasing his sentence to the maximum penalty due to the presence of aggravating circumstances of treachery (alevosia) and commission in an uninhabited place (despoblado), while acquitting Jose Acquebay due to insufficient evidence.