Facts:

This case revolves around a violent confrontation between two families in the municipality of Urbiztondo, Pangasinan, specifically between the Agbuyas and the Palisocs, stemming from longstanding animosity. On August 10, 1930, Hipolito Agbuya was found cleaning his shotgun by a neighbor, Padua, who had come to visit. Later that day, Hipolito and his son Agustin set out for the market in Maliuer while Martin Palisoc and his companion, Emilio, were there as well. In a fateful encounter near their home, Agustin Agbuya, upon receiving the shotgun from his father, confronted Martin Palisoc stating, "Now, Don Martin, the end of your life has come," before shooting him. As Martin fell, he was joined by his brother Feliciano, who also became a target of Agustin's gunfire and subsequently died. Additional witnesses confirmed that Agustin continued firing upon Pioquinto Palisoc, who narrowly escaped injury. The Agbuyas' actions were marked with intent, and subsequently,

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Facts:

Background of Hostilities

• A long-standing enmity existed between the two prominent families, the Palisocs and the Agbuyas, in the municipality of Urbiztondo, Pangasinan.
• The mutual hatred and feud set the stage for the violent confrontation that ensued.

Pre-Offense Circumstances

• For several years, hostilities between the families had escalated tensions in the community.
• On the morning of August 10, 1930, a neighbor named Padua visited the residence of Hipolito Agbuya and observed him cleaning his shotgun.
• During the visit, Hipolito inquired about the whereabouts of Martin Palisoc, indicating premeditated interest in his target.

Initial Movements and Convergence

• After the visit, Hipolito, accompanied by his son Agustin, proceeded to the barrio of Maliuer where they engaged in selling cloths at the market.
• Simultaneously, Martin Palisoc, together with his brother Emilio Palisoc, also visited Maliuer to attend to personal duties.
• Their paths converged when both parties were seen in proximity at the market, setting the stage for the impending confrontation.

The Ambush on the Malecon

• Between 2:00 and 3:00 in the afternoon, Hipolito and Agustin passed along a malecon, with Hipolito carrying his shotgun and Agustin armed with a bolo.
• Martin Palisoc, accompanied by Emilio Palisoc and Raymundo Poquis, was seen moving along the same route on a similar path.
• After a short distance, Hipolito and Agustin deviated from the main path by stepping aside and waiting hidden near banana and bamboo trees to prepare an ambush.

The Confrontation and Sequence of Shootings

• As Martin Palisoc and his companions approached, Hipolito and Agustin adjusted their positions strategically along the malecon.
• Agustin unsheathed his bolo but then quickly dropped it and requested the shotgun from his father, indicating a prearranged plan.
• Upon receiving the gun, Agustin confronted Martin Palisoc with the declaration, “Now, Don Martin, the end of your life has come,” and fired, causing Martin to fall.
• Raymundo Poquis and Emilio Palisoc initially fled the scene, but soon after, Raymundo alerted Feliciano Palisoc by shouting that an attack had occurred.
• Feliciano Palisoc, while approaching the scene from a distance (about sixty meters away), was also shot by Agustin, which resulted in his immediate death or near-instant fatality.
• Shortly thereafter, Pioquinto Palisoc arrived and attempted to assist by searching for Martin. Observing Agustin discharge his shotgun at Feliciano, Pioquinto retreated for cover but was then targeted from approximately two hundred meters away.
• In a frantic effort to protect or salvage Martin, Pioquinto tried to assist him; however, Agustin shot at Martin once more, contributing to Martin’s fatal injury.
• After the shootings, the Agbuyas—Hipolito, Agustin, and a third individual identified as Pauetino Agbuya—approached the dying Martin and the body of Feliciano while vociferously threatening, “Come on, you Palisocs. We are going to exterminate you.”

Aftermath and Arrest

• The Agbuyas vigilantly guarded the scene with the bodies throughout the remainder of the afternoon, only leaving when police arrived after dark.
• The following morning, during daylight, Constabulary officers arrested Hipolito and Agustin Agbuya in Lingayen as they disembarked from an automobile at an attorney’s residence where they sought legal representation.
• In custody, Hipolito openly conceded guilt stating, “I know why you have come, and it is because we are guilty,” and acknowledged that they had shot Martin and Feliciano Palisoc.

Issue:

Question of Principal Liability

• Whether Hipolito Agbuya, despite claims of non-participation as a principal in the actual shootings, should be held equally accountable given his preparatory and contributory actions.

Nature of the Offense Against Martin Palisoc

• Whether the killing of Martin Palisoc constitutes murder due to the element of surprise, despite the absence or non-apparent presence of alevosia.
• Consideration of whether the circumstances reflect premeditation sufficient for a murder charge.

Qualification of the Offense of Illegal Discharge of Firearms

• Whether Agustin Agbuya’s act of discharging the shotgun from a significant distance at Pioquinto Palisoc, with the intent seemingly more to intimidate than to kill, justifies the specific legal characterization and penalty.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)