G.R. No. 6659 - People vs Baggay, Jr.

On or about the 4th of October, 1909, several persons gathered at the defendant’s residence in the township of Penarrubia, Abra, in the Province of Ilocos Sur, for a song service called "buni" in accordance with Tinguian custom.
During the gathering, the defendant, a non-Christian identified as Baggay, Jr., without any provocation, suddenly attacked the woman Bil-liingan using a bolo.
He inflicted a severe head wound on Bil-liingan which resulted in her immediate death.
In addition to Bil-liingan, he also attacked several other persons: the women Calbayan, Agueng, Quisamay, Calapini, and his own mother, Dioalan, by inflicting various wounds with his bolo.

The provincial fiscal filed a complaint dated February 15 charging Baggay, Jr. with murder based on the violent death of Bil-liingan.
The complaint, concerning the charge of murder, was instituted separately from another case (No. 1109) filed for lesiones.

At trial, evidence was presented showing that the defendant was suffering from mental aberration (insanity).
On April 28, 1910, the trial judge rendered a judgment declaring Baggay, Jr. exempt from criminal liability on account of his mental condition.
Notwithstanding the exemption from criminal liability, the judgment imposed civil obligations on him:

He was ordered to indemnify the heirs of the murdered woman, Bil-liingan, in the sum of P1,000.
He was condemned to pay the costs of the case.
He was further ordered to be confined in an institution for the insane until further notice by the court.

Counsel for the defendant promptly appealed the judgment, raising issues regarding:

The immediate suspension of execution of the judgment while the appeal was pending.
The annulment of the sale at public auction of property attached by the sheriff (or his deputy) and asserting that the attachment was erroneously executed upon the property of Dioalan and other persons, not upon the defendant’s property.

The appeal was submitted beyond the time limit, arguing that the defendant’s counsel had been verbally notified of the judgment on April 28, 1910.
The written notice on June 17, 1910, was a mere formality and did not alter the fact that notification was effectively given earlier.

Declaring the appeal as out of order and dismissing it on August 2, 1910.
Denying the petition for suspension of the judgment, with the reasoning that the judgment had already become final.

In response, the defendant’s counsel sought a writ of mandamus, specifically requesting:

That Judge Chanco of the Court of First Instance be directed to admit the appeal and forward the case records to the higher court.
That all actions for the execution of the judgments in the murder and lesiones cases be annulled during the pendency of the appeals.

The Attorney-General, representing the judge and the provincial fiscal, contended that:

Issuance of a writ of mandamus against the judge and provincial fiscal was not supported by law.

Issued a writ, on November 15, ordering the admission of the appeal and the immediate forwarding of the case records.
Directed the trial judge, the provincial sheriff, and other officers to suspend all actions for executing the judgments pending further orders.

Consequently, on November 22, the trial judge admitted the appeal in both the murder and lesiones causes.

Whether the defendant, Baggay, Jr., although declared legally insane and exempt from criminal liability, is nonetheless civilly liable for the damages resulting from his actions.

Does the exemption from criminal liability due to mental aberration also exempt him from civil liability?
Can the state impose the obligation to indemnify the heirs of the murdered woman and the duty to pay the case costs despite his declared insanity?

The propriety of executing attachments on properties not belonging to the defendant, particularly when such attachments involve the property of other individuals (e.g., Dioalan).

Whether the attachment of properties was in accordance with the legal requirements given the nature of the appeal and the conditions of the judgment.

Whether the defendant’s counsel was properly notified of the judgment so as to validate or invalidate the timeliness of the appeal.
Whether the trial court’s dismissal of the appeal and the denial of the petition for suspension were correct in light of procedural and substantive legal norms.