Title
People vs. Kiichi Omine
Case
G.R. No. 42476
Decision Date
Jul 24, 1935
Defendants accused of frustrated homicide after a confrontation over destroyed hemp plants; court acquits three, convicts one for serious injury.

Case Digest (G.R. No. 42476)

Facts:

  • Relationship and Employment of the Defendants
    • The case involves four defendants: Kiichi Omine, Eduardo Autor, Luis Ladion, and Agapito Cortesano.
    • Eduardo Autor, Luis Ladion, and Agapito Cortesano were employed on Angel Pulido’s hemp plantation under the supervision of Kiichi Omine, who received a ten percent commission of the gross receipts.
    • All four lived together in a house located on the plantation.
  • The Road Construction Controversy
    • Kiichi Omine requested permission from Angel Pulido to open a new road through the plantation.
    • According to Angel Pulido, he refused the request because an unfinished road already existed, whereas Omine claimed that permission was granted and work commenced on December 24, 1933.
    • On that same day, when Angel Pulido, his son Hilario Pulido, and their companions were returning from the cockpit, they discovered that a significant number of hemp plants had been destroyed to make way for the new road.
  • The Confrontation and Altercation
    • Infuriated by the destruction of his hemp plants, Angel Pulido, accompanied by his son and aides (Saito Paton and a Moro named Barabadan), went to the defendants’ residence shortly after supper.
    • Conflicting versions of events emerged:
      • The prosecution’s witnesses asserted that during the confrontation, while Angel Pulido was speaking with Omine, Eduardo Autor attempted to intervene. Hilario Pulido prevented such intervention, then Eduardo Autor attacked Angel Pulido with his bolo, resulting in a serious wound.
      • Defense witnesses contended that Angel Pulido and his son instigated the fight. Hilario Pulido allegedly struck Omine with brass knuckles after hurling an offensive epithet; upon Eduardo Autor’s attempt to intervene, Angel Pulido and his son attacked him, with the resulting blow coming during this escalated melee.
    • Ladion and Cortesano were alleged by the offended party to have restrained him, but their exact role remains uncertain as evidence suggests they might have fled the scene, and they were not initially named in the original complaint until its amendment.
  • The Evidence and Witness Testimonies
    • Eyewitnesses for the prosecution included Angel Pulido, his son, and a relative named Saito (a Bagobo). However, Barabadan was not presented as a witness.
    • The defendants themselves provided testimony in their defense.
    • A notable detail in the factual matrix is the single wound received by Angel Pulido—a cutting wound approximately eleven inches long, extending from the breast to the lower ribs on the right side—indicating a blow given during a commotion rather than a targeted stab meant to kill.
  • Context of the Dispute and the Physical Injury
    • The altercation appears to have been set off by the unauthorized destruction of the hemp plants rather than by a planned homicidal scheme.
    • The evidence indicates that the aggressive encounter escalated due to miscommunications and conflicting narratives regarding who instigated the violence.

Issues:

  • Liability and Participation of the Defendants
    • Whether all the defendants, particularly Kiichi Omine, Luis Ladion, and Agapito Cortesano, should be held accountable for the injury sustained by Angel Pulido under the theory of criminal complicity or inducement.
    • The extent to which the involvement of Ladion and Cortesano is supported by the evidence, especially in light of their alleged absence during crucial moments and late inclusion in the complaint.
  • Determination of Criminal Intent
    • Whether Eduardo Autor acted with the specific intent to kill (a requisite for frustrated homicide) based on the nature and location of the wound inflicted on Angel Pulido.
    • Whether the evidence supports the prosecution’s theory that the injury was inflicted under the influence or direct inducement by Kiichi Omine.
  • Role and Effect of Inducement
    • Whether the alleged words of encouragement (“pegale y matale”) by Kiichi Omine, if uttered, were sufficient to constitute direct inducement leading to the commission of an offense.
    • The application of jurisprudence on direct inducement to determine if such words could legally impose liability on Omine and, by extension, on the other co-defendants.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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