Case Digest (G.R. No. L-7618-20)
Facts:
The People of the Philippines v. Crispin Lawas, Agustin Osorio and Clemente Osorio; The People of the Philippines v. Crispin Lawas, Agustin Osorio and Clemente Osorio; The People of the Philippines v. Felipe Si-it, Generoso Osorio and Patricio Pinos, G.R. Nos. L-7618-20, June 30, 1955, the Supreme Court En Banc, Labrador, J., writing for the Court.The criminal proceedings arose from a July 1942 series of events in Lanao province. On July 3, 1942, a group of Maranao Muslims from Barrio Baris raided Barrio Malingao, killing eleven Christian residents, wounding two, and taking property. The incident was reported to local home guards — a local peacekeeping body composed of ex-PC soldiers and civilians — including appellant Crispin Lawas, head of the home guards in Balimbing, and Sgt. Benaojan, head of home guards in Salong.
On July 10, 1942 Lawas, Benaojan and other home guards proceeded to Barrio Baris, rounded up various Maranaos (men, women and children) and brought them to Barrio Salong that evening. During their presence in Baris some animals and personal property were taken from the Maranaos; the taking formed the basis of robbery charges. The Maranaos were detained overnight in the house of Restituto Requino. On the morning of July 11, Lawas and Agustin Osorio conducted an investigation by questioning groups of Maranaos before a table near a rice mill. A commotion erupted while they questioned the detainees; gunfire then ensued, during which many of the Maranaos on the ground were killed. Separately, persons (some identified as home guards and others unidentified) ascended to the second floor of Requino’s house and attacked the women and children there; at least 35 women and children were killed and others stabbed.
Criminal informations were filed: a robbery charge (Crim. Case No. 180; G.R. No. L-7618) charging various appellants with taking animals and personal effects; and two informations for multiple murder (Crim. Case Nos. 444 and 373; referenced in the opinion as G.R. Nos. L-7613 and L-7620) charging different groupings of appellants with the killings. At trial in the Court of First Instance of Lanao the defendants were convicted: in the robbery case each convicted and fined/ordered to indemnify; in the murder cases several defendants were found guilty of multiple murder and sentenced to indeterminate terms and ordered to indemnify the heirs.
Several defendants appealed to this Court. Some appeals (notably those of Agapito Gumisad and Hermenegildo Tabacon) were dismissed for failure to file briefs; others proceeded. On appeal the Supreme Court reviewed the record of the Court of First Instance and the testimony of eyewitnesses (including Manaronsong Lomangcolob and...(Pro-only)
Issues:
- Whether the convictions for robbery should be affirmed and whether the accused acted pursuant to a conspiracy or should be held individually liable.
- Whether the killings of the Maranaos constitute murder or merely homicide, and whether the appellants (including leaders Lawas and Agustin Osorio) can be held individually liable for the murder of the women and children in Requino’s house (including liability by inducement).
- Whether each defendant may be convicted for as many offenses as there were victims or for a single offense arising from a single criminal impulse ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)