Facts:

The case involves two sets of defendants, Dinulon and Bimusao in G.R. No. 23417, and Daoyan and Taeg in G.R. No. 23418, who were charged with murder and attempted murder, respectively. The events took place on or about April 20, 1924, in the sitio of Mangayan, subprovince of Ifugao, Mountain Province, Philippines. The defendants belonged to the Balangao tribe, while the victims, Palaad and his son Bonhaon, were from the Mayaoyao tribe. A longstanding feud existed between these two tribes, which was exacerbated by the murder of Balengua, a relative of Dinulon, by members of the Mayaoyao tribe. In retaliation, Dinulon initiated a head-hunting expedition with the other defendants to avenge Balengua's death.

During this expedition, the defendants ambushed Palaad and Bonhaon as they traveled along a path. Palaad was killed, and his head was severed and taken by Dinulon. Bonhaon managed to escape and reported the incident to the authorities, leading to the filing of complain...

Facts:

Background of the Case

• The case involves two separate criminal actions:
  1. G.R. No. 23417: The People of the Philippine Islands vs. Dinulon and Bimusao (murder of Palaad).
  2. G.R. No. 23418: The People of the Philippine Islands vs. Daoyan and Taeg (attempted murder of Bonhaon).
• The defendants (Dinulon, Bimusao, Daoyan, and Taeg) belonged to the Balangao tribe, a non-Christian tribe in northern Luzon.
• The victims, Palaad and his son Bonhaon, belonged to the Mayaoyao tribe, another non-Christian tribe.
• A longstanding feud existed between the Balangao and Mayaoyao tribes, rooted in the custom of "a head for a life."

Incident Leading to the Crime

• Prior to the incident, Balengua, a member of the Balangao tribe and a relative of Dinulon, was killed by members of the Mayaoyao tribe.
• Dinulon and the other defendants conspired to avenge Balengua's death by organizing a head-hunting expedition.
• In April 1924, the defendants ambushed Palaad and Bonhaon in the sitio of Mangayan, Ifugao.
  • Palaad was killed, and his head was severed and carried away.
  • Bonhaon escaped unharmed and reported the incident to authorities.

Legal Proceedings

• Complaints were filed on May 5, 1924, charging the defendants with murder and attempted murder.
• After a preliminary examination, the cases were elevated to the Court of First Instance.
• The defendants were tried together, and the court found:
  • Dinulon and Bimusao guilty of murder with evident premeditation, treachery, and cruelty.
  • Daoyan and Taeg guilty of attempted murder with evident premeditation and treachery.
• The defendants were sentenced accordingly and appealed the decision.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Credibility of Evidence:

   • The prosecution's evidence, particularly the testimony of Bonhaon and the confessions of the defendants, was credible and sufficient to establish guilt beyond reasonable doubt.
   • The defense's claim of torture was deemed improbable, as it was unlikely that such acts would be carried out publicly.

2. Admissibility of Exhibits:

   • Exhibits A, B, and C (weapons used in the crime) were properly identified and admitted as evidence.
   • Exhibits E, F, G, and H (confessions) were deemed voluntary and admissible, as they were ratified by the defendants in the presence of authorities.

3. Application of Penal Code:

   • The crimes were qualified by evident premeditation and aggravated by treachery and cruelty.
   • However, the mitigating circumstance of lack of education and instruction (Article 11 of the Penal Code) was applied to offset the aggravating circumstances.