Facts:

The case involves the People of the Philippine Islands as the plaintiff and Eulogio Espenilla et al. as the defendants, with the decision rendered on October 8, 1935, by the Supreme Court of the Philippines. The appellants were tried in the Court of First Instance of Leyte for the murder of Simplicio Tomandao. The trial court found the seven appellants guilty of homicide, sentencing them to penalties ranging from eight years and one day of prision mayor to fourteen years, eight months, and one day of reclusion temporal, along with an indemnity of P1,000 to the heirs of the deceased and the payment of costs. The prosecution's narrative indicated that on March 21, 1935, around 4 PM, a group was playing "heads or tails" in the barrio of Tagkip, Burauen, where Eusebio Bueno was a participant. Felix Sosing, who was present but not participating, became involved in a dispute with Romualdo Idara over a request for change. Simplicio Tomandao intervened, attempting to me...

Facts:

Background of the Incident

• On March 21, 1935, in the barrio of Tagkip, Burauen, Leyte, a group of people were playing "heads or tails" with coconut shells. Eusebio Bueno was one of the players, while Felix Sosing was present but did not participate.
• Romualdo Idara attempted to get change for ten centavos, which Bueno perceived as a disturbance. Bueno knocked Idara down, and Simplicio Tomandao intervened to calm the situation. Bueno resented Tomandao's intervention and threatened him, saying they would meet later.

The Attack

• About two hours later, Felix Sosing, accompanied by six co-accused (including Eulogio Espenilla), went to Felix Cuizon's house, where Tomandao was eating. Sosing demanded that Tomandao come out, but Cuizon denied his presence.
• Sosing entered the house armed with a shotgun and a bolo, pointing the gun at Tomandao. Tomandao fled through a hole in the house, but upon landing, Espenilla stabbed him in the abdomen. Sosing struck Tomandao on the head with a bolo, and Bueno knocked him down with a stick. The other defendants joined in, attacking Tomandao with sticks and bolos, resulting in his immediate death.

Defense's Version

• The defense claimed that Sosing went to Cuizon's house to investigate reports of illegal cockfighting, as he was a government agent tasked with stopping such activities. Upon arrival, he found Cuizon, Tomandao, and Sotero Lastimado.
• Sosing questioned Cuizon about the cockfighting, and Tomandao intervened aggressively, drawing his bolo and wounding Sosing on the arm. Espenilla arrived and engaged in a fight with Tomandao, ultimately killing him in self-defense.

Medical Evidence

• A provincial sanitary inspector testified that Sosing and Espenilla had wounds consistent with their claims of being attacked by Tomandao. Espenilla admitted to killing Tomandao but argued it was in self-defense.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Insufficient Evidence for Conspiracy: The prosecution failed to prove that the appellants conspired to kill Tomandao. The motive alleged (Tomandao's intervention in a minor dispute) was insufficient to justify the claim of a premeditated attack.
2. Self-Defense Not Proven: While Espenilla claimed self-defense, the Court found his testimony unconvincing. The number and severity of Tomandao's wounds, compared to Espenilla's minor injury, suggested that Espenilla was not acting purely in self-defense.
3. Mitigating Circumstances: Espenilla was entitled to mitigating circumstances due to his voluntary surrender and lack of education, which reduced his culpability.
4. Acquittal of Other Defendants: The evidence did not establish the involvement of the other appellants in the crime, leading to their acquittal.