Case Digest (G.R. No. L-2631)
Facts:
- Alipio Baluyut, an elderly man from Barrio Del Carmen, Lubao, Pampanga, was murdered in July 1944.
- He was the father of Eloy Baluyut, a guerrilla officer in the USAFFE, making him a target for the Hukbalahap organization.
- On July 3, 1944, a meeting led by Simplicio Gonzales in Barrio Kabankalan resulted in a petition to liquidate Alipio, signed by several individuals, including Jose Lumanlan.
- Armed members of the Hukbalahap, including Lumanlan, forcibly kidnapped Alipio from his home, witnessed by his daughter, Jovita.
- After the war, Eloy Baluyut, who became mayor in 1946, apprehended some culprits who revealed Alipio's burial site.
- Jose Lumanlan was arrested in 1947 and confessed to the kidnapping and murder of Alipio.
- The trial court found Lumanlan guilty of murder, sentencing him to reclusion perpetua and ordering monetary indemnity to Alipio's heirs.
- Lumanlan appealed, claiming he acted under duress from the Hukbalahap.
Issue:
- (Unlock)
Ruling:
- The court ruled that Jose Lumanlan did not act under duress and was guilty of murder.
- The trial court's rejection of Lumanlan's defense of involuntariness was upheld.
- Lumanlan was not ent...(Unlock)
Ratio:
- The Supreme Court affirmed the trial court's decision, finding Lumanlan's duress claim unconvincing.
- As a chief member of the Hukbalahap, Lumanlan had the authority to oppose the liquidation petition but chose to participate.
- His actions were inconsistent with a defense of involuntariness, as he ...continue reading
Case Digest (G.R. No. L-2631)
Facts:
The case revolves around the murder of Alipio Baluyut, an elderly man residing in Barrio Del Carmen, Lubao, Pampanga, during the tumultuous period of July 1944. Alipio was the father of Eloy Baluyut, a guerrilla officer in the USAFFE, which made him a target of the Hukbalahap organization due to his perceived lack of sympathy towards their cause. On July 3, 1944, a meeting was convened by Simplicio Gonzales, alias Filipinas, in Barrio Kabankalan, where a petition was presented, signed by several individuals including the accused, Jose Lumanlan, alias Morada, requesting the liquidation of Alipio Baluyut. Following this assembly, armed members of the Hukbalahap, including Lumanlan, forcibly entered Alipio's home, where they kidnapped him in the presence of his daughter, Jovita. Despite her attempts to intervene, Alipio was taken away, and Jovita overheard the assailants ominously stating that her father's end had come. After the war, in 1946, when Eloy Baluyut became mayor, he managed to apprehend some of the culprits, who led him to the location of Alipio's remains. Jose Lumanlan was arrested in 1947 and confessed to his involvement in the kidnapping and murder, detailing how they killed Alipio and buried him. The trial commenced against Lumanlan after the others had already been convicted. The...