People v. Angel
REITERATIONFacts
The Antecedents: On the morning of May 18, 1899, at approximately 3 o'clock, defendants Engracio Angel and Pablo Angel boarded a banca near Malabon, Province of Rizal. Aboard the banca were Manuel Garcia, his wife Leonarda Geronimo, their seven-year-old daughter Rosa Garcia, Rufino Dizon, and Jose Castillo. The defendants bound the men, demanded money from Leonarda Geronimo, and upon her inability to provide more after giving 14 pesos, they seized her and her child. Leonarda was taken to the stern of the boat, thrown into the hold where pigs were kept, and fatally struck with bolos, sustaining wounds to the neck and severed hands. The child, Rosa Garcia, was taken from the hold alive but died fourteen days later, her condition deteriorating despite care, with the cause of death unknown. Saturnino Angel remained on shore, watching Roberto Oliveros, and intermittently shouted reassurances in Tagalog. Procedural History: The provincial fiscal of Rizal charged Engracio Angel, Pablo Angel, and Saturnino Angel with double murder. The court, on April 29, 1904, sentenced all three defendants to cadena perpetua, to indemnify the heirs of the deceased in the sum of 1,000 pesos, and to pay the costs. The Petition: The defendants appealed their conviction.
Issue(s)
Whether the defendants are guilty of the crime of murder. Whether the death of the child, Rosa Garcia, is attributable to the acts of the defendants. Whether the robbery committed prior to the murder should be considered.
Ruling
The Supreme Court affirmed the judgment of the lower court, finding the three defendants guilty of murder. They were sentenced to cadena perpetua, with the accessories of the law, to jointly and severally indemnify the heirs of the deceased Leonarda Geronimo in the sum of 1,000 pesos, and to pay one-third of the costs each. The Court abstained from considering the death of the child and the robbery committed, as they were not the subject of the complaint or sufficiently proven to be a direct result of the defendants' actions.
Ratio Decidendi
On the guilt of the defendants for the murder of Leonarda Geronimo: The Court found the commission of murder fully proven. Leonarda Geronimo was a victim of the weaker sex, defenseless on board the boat. The attack was sudden and perpetrated by two armed men, making defense or flight difficult, if not impossible. This established the circumstance of treachery (alevosia). The Court held that all three defendants, Saturnino, Engracio, and Pablo Angel, were equally liable as principals. Engracio and Pablo committed the physical act of murder, while Saturnino, by remaining on shore to watch, aid, and abet his co-defendants, and by guarding them from surprise, directly cooperated in the execution of the crime. This demonstrated a conspiracy and prior understanding among the defendants to carry out the crime. The testimony of eyewitnesses and Roberto Oliveros corroborated the commission of the assault and aggression against Leonarda. On the death of the child, Rosa Garcia: The Court abstained from considering the death of the young girl, Rosa Garcia, which occurred fourteen days after the affray. There was insufficient evidence to prove that her death resulted directly from being thrown into the hold. Therefore, this fact was not considered in the opinion. On the robbery committed: The Court stated that it would not take into consideration the robbery committed by the defendants before the murder of Leonarda. This was because the robbery was not the subject of the complaint filed by the fiscal. The prosecution focused solely on the crime of murder.
Main Doctrine
Conspiracy to commit murder, where one conspirator acts as a lookout and guard while others perpetrate the killing, renders all conspirators equally liable as principals. The aggravating circumstance of nocturnity, when counterbalanced by the special conditions prevailing during a period of disorder, results in the imposition of the penalty in its medium degree.