G.R. No. L-38169 - People vs. Sabater

This case is an automatic review by the Supreme Court of the decision of the defunct Court of First Instance of Basilan (Presiding Judge Jainal D. Rasul), convicting Julaide Siyoh and Omarkayam Kiram of qualified piracy with triple murder and frustrated murder under Presidential Decree No. 532.
Co-accused Namli Indanan and Andaw Jamahali remained at large; only Siyoh and Kiram were apprehended, tried and convicted.

On July 14, 1979, at or near Mataja Island, Municipality of Lantawan, Basilan, the accused—armed with firearms (“barongs” for Siyoh and Kiram; armalites for their confederates)—intercepted a pumpboat carrying four merchants: Rodolfo de Castro, Danilo Hiolen, Anastacio de Guzman and Antonio de Guzman.
They fired into the air, boarded the vessel, robbed the victims of P18,342.00 and personal effects, ordered them to jump into the water, then hacked three to death and shot Antonio de Guzman, who survived by swimming ashore.

The trial court found the guilt of Siyoh and Kiram proven beyond reasonable doubt, sentenced each to death, but recommended commutation to life imprisonment under Section 106 of the Code of Mindanao and Sulu due to illiteracy and extreme poverty.
On appeal, the sole assignment challenged the sufficiency of evidence. The Supreme Court affirmed the conviction, modified the penalty to reclusion perpetua (for lack of the necessary votes for death), and imposed solidary indemnity of P30,000.00 to the heirs of each deceased victim.

Whether the trial court rightly credited the lone prosecution eyewitness, Antonio de Guzman, over the appellants’ denials.

Whether the record establishes a common design among the accused to commit piracy and murder.