People v. Manalinde
REITERATIONFacts
The Antecedents: On January 19, 1909, between 2 and 3 o'clock in the afternoon, Juan Igual, a Spaniard, was seated in the doorway of Sousa's store in Cotabato when he was suddenly struck from behind with a kris, receiving a wound on the head. Ricardo Doroteo, a store clerk, heard the commotion and found Igual on the ground. The aggressor, identified as the Moro Manalinde, then approached a Chinaman named Choa, who was passing by and placing down a load in front of a store. Manalinde attacked Choa with the same kris, inflicting a severe wound in the left shoulder, causing Choa to fall and subsequently die within an hour at the hospital. Manalinde, who came from Dupit and had entered the town carrying his weapon concealed in banana leaves, escaped. Procedural History: Following the incident, the provincial fiscal filed a complaint charging Manalinde with murder. The trial court, after considering the evidence, rendered judgment on February 5, 1909, sentencing the accused to death, to indemnify the heirs of the deceased Choa in the amount of P1,000, and to pay the costs. The case was elevated to the Supreme Court for automatic review. The Appeal: The case was submitted to the Supreme Court for review of the judgment of the trial court, which found the accused guilty of murder and imposed the death penalty. The defense, represented by Ramon Diokno, likely argued for acquittal or a lesser penalty, while the prosecution, represented by the Office of the Solicitor-General Harvey, sought to uphold the conviction and sentence.
Issue(s)
Whether the accused, Moro Manalinde, is guilty of the crime of murder. Whether the qualifying circumstance of treachery was present in the killing of Choa. Whether the aggravating circumstances of promise of reward and evident premeditation were present. Whether the defense of acting as a 'juramentado' under orders can exculpate the accused.
Ruling
The Supreme Court affirmed the judgment of the trial court, sentencing the accused, Moro Manalinde, to the penalty of death, to indemnify the heirs of the deceased in the sum of P1,000, and to pay the costs. The Court ordered that the penalty be executed in accordance with Acts Nos. 451 and 1577, and that in the event of a pardon, he shall also suffer the accessory penalties imposed by article 53 of the Penal Code.
Ratio Decidendi
On Issue 1: The Supreme Court affirmed the conviction for murder, finding that the crime was committed on the person of the Chinaman Choa. The Court noted that the deceased was unexpectedly and suddenly attacked, receiving a deep cut on the left shoulder at the moment he was placing down his load and about to enter a store. The severity of the wound, inflicted by a heavy and unexpected blow, rendered the victim unable to defend himself or flee, leading to his death within an hour. The Court found that the means and form employed in the attack consummated the violent death with deceit and treachery, which is a qualifying circumstance for murder under Article 403 of the Penal Code. On Issue 2: The Court held that treachery (alevosia) was present in the commission of the crime. The attack on Choa was sudden and from behind, while the victim was occupied with placing down his load and was about to enter a store. This manner of attack ensured that the victim had no opportunity to defend himself or to escape the danger, thus satisfying the definition of treachery as a qualifying circumstance that calls for the imposition of the greatest penalty. On Issue 3: The Court found the aggravating circumstances of promise of reward and evident premeditation to be present. The accused confessed that he acted upon the order of Datto Mupuck to go juramentado and kill someone, with the promise of a pretty woman upon his return if successful. This constitutes a promise of reward. Furthermore, the accused's deliberate consideration of the act, his journey of a day and a night, and his provision of a concealed weapon demonstrated a firm and persistent intention to carry out the crime, thus establishing evident premeditation. The Court noted that even though the victims were not specifically predetermined, the deliberate planning and execution of the act to take the lives of two persons indicated premeditation. On Issue 4: The Court unequivocally rejected the defense that acting as a 'juramentado' under orders from Datto Mupuck could exculpate the accused. The Court stated that such an excuse cannot be accepted under the laws of civilized nations, as these acts of ferocity and savagery must be restrained. The established authorities in the country would not allow such crimes to go unpunished, and the punishment of the author has followed every crime so committed. The Court emphasized that the accused acted of his own volition and with knowledge of the irreparable injury he would inflict, and that both the instigator and the perpetrator knew that punishment was a possibility.
Main Doctrine
The Supreme Court affirmed the conviction for murder, holding that the qualifying circumstance of treachery was present due to the sudden and unexpected attack from behind. The Court also found the aggravating circumstances of promise of reward and evident premeditation, emphasizing that the accused's deliberate planning, acquisition of a weapon, and journey to commit the crime demonstrated a firm and persistent intent, even though the victims were not specifically known beforehand. The defense of acting as a 'juramentado' under orders was unequivocally rejected as a valid excuse under the law.