Facts:

The case revolves around the complaint filed on April 4, 1904, by the provincial fiscal of Rizal against Engracio Angel (also known as Feliciano Angel), Pablo Angel, and Saturnino Angel, charging them with double murder. The incident took place on May 18, 1899, on a banca anchored near Bacog in Malabon, Rizal. On that morning, the two defendants, Engracio and Pablo, approached the banca occupied by Manuel Garcia, his wife Leonarda Geronimo, their young daughter Rosa Garcia, and two others, Rufino Dizon and Jose Castillo. They bound the men and demanded money from Leonarda, to which she responded by handing over 14 pesos. Dissatisfied, the defendants proceeded to search the banca for more money. When Leonarda could not provide any further funds, they seized her, throwing her into the hold of the boat along with her child. Inside the hold, they brutally assaulted Leonarda with bolos, inflicting fatal injuries. Although Rosa was initially taken out alive, she suffered dramatically

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Facts:

Incident Background

• The case involves a complaint filed on April 4, 1904, by the provincial fiscal of Rizal charging three defendants—Engracio Angel (also known as Feliciano Angel), Pablo Angel, and Saturnino Angel—with double murder.
• The crime occurred on the morning of May 18, 1899, aboard a banca (a small boat) anchored near Bacog in the town of Malabon, Rizal.

Details of the Crime

• The defendants boarded the banca where Manuel Garcia, his wife, Leonarda Geronimo, their 7-year-old daughter Rosa Garcia, and two other passengers, Rufino Dizon and Jose Castillo, were present.
• Engracio and Pablo Angel bound the male passengers and forced them into a prone position.
• They extorted money from Leonarda Geronimo by demanding all her cash; she initially surrendered 14 pesos.
• After searching and failing to locate additional funds in the trunks, the perpetrators demanded more money, leading to further conflict.

The Murder of Leonarda Geronimo

• With no additional money obtainable, Engracio and Pablo seized Leonarda, took her to the stern of the boat along with her child in her arms, and confined her in the hold where pigs were kept.
• They struck her on the head repeatedly with bolos; the blows resulted in her death.
• The victim was further mutilated as evidenced by injuries, including a cut on the neck and the severing of both hands.

Subsequent Events Involving the Young Child

• Although Rosa Garcia, the young daughter, was rescued alive from the hold, she later lost her appetite and became emaciated.
• Despite attempts to nurse her with milk, she ultimately died fourteen days after the initial assault, though the direct cause of her death was not conclusively linked to being thrown into the hold.

Saturnino Angel’s Role

• Unlike Engracio and Pablo who boarded the banca, Saturnino remained on shore by the bank of the river.
• He was actively involved by watching the events, assisting in the execution of the crime by preventing any interference, and even urging the captive, Roberto Oliveros, to shout “Don’t be afraid.”
• His conduct contributed to the overall criminal enterprise by guarding the perpetrators and ensuring the act was carried out without interruption.

Evidentiary Elements and Circumstances

• Testimonies of two eyewitnesses and corroborative statements by Roberto Oliveros established the occurrence of the assault and the subsequent discovery of Leonarda Geronimo’s body.
• The use of treachery (alevosia) in the crime was emphasized since Leonarda was considered defenseless on the boat.
• The crime was additionally aggravated by the circumstance of nocturnity, although this factor was balanced by special conditions prevailing at the time, including civil disorder and resistance by local inhabitants.

Issue:

Legal Sufficiency of Evidence

• Whether the evidence adduced by the prosecution, especially the testimonies of the eyewitnesses and the corroborative statement of Roberto Oliveros, was sufficient to establish the guilt of the defendants in the murder of Leonarda Geronimo.
• Whether the indirect involvement of Saturnino Angel, who remained ashore, constituted enough participation to render him equally liable as a principal in the crime of murder.

Causation of the Young Girl’s Death

• Whether the death of Rosa Garcia, which occurred fourteen days after the assault, could be legally attributed to the actions committed during the boarding of the banca.
• Whether the absence of direct evidence linking her death to the criminal act should affect the final judgment regarding the prosecution’s charge.

Consideration of Aggravating and Mitigating Circumstances

• Whether the qualifying circumstance of treachery combined with the mode of the crime (using cutting and blunt weapons) demands a penalization corresponding to a severer penalty as provided under article 403 of the Penal Code.
• Whether the aggravating factor of nocturnity, when balanced against the mitigating conditions (civil disorder, resistance by townspeople, and special conditions at the time), justifies imposing a penalty of medium degree.

Appropriateness of the Sentencing

• Whether the sentence of cadena perpetua (life imprisonment) with accessories, and the additional penalties (indemnification of 1,000 pesos and costs) imposed on the accused, adequately reflect the gravity as well as the specific circumstances surrounding the crime.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)