G.R. No. 5161 - People vs Beecham

On June 1, 1908, an information was filed in the Court of First Instance of Pampanga charging Mike Beecham with murder.
The information alleged that on May 11, 1908, at Camp Stotsenberg, Pampanga, the defendant discharged his firearm at various members of Troop F, killing Sergeant William Hoey, Privates Thomas F. Woodward, George Wilson, and Edward T. Clark.
For convenience of trial, the prosecution obtained leave to sever the original single charge into separate complaints for each shooting, to which the defendant pleaded not guilty in all instances.
A stipulation was entered between the Government and the defendant’s counsel that the evidence presented in one case (No. 589, R.G. No. 5161) would apply to the other related cases (Nos. 609, 610, and 611).
On October 29, 1908, the trial court found the defendant guilty of the charge(s) and sentenced him to cadena perpetua with a maximum imprisonment term not to exceed 40 years, with all four sentences to be served simultaneously.

The incident occurred on May 11, 1908, during the noon period after the men of Troop F had taken their meal.
The layout of the barracks is described in detail, involving a mess room with a window (marked “1”), a squad room (marked “6”), a dining room, a connected covered passageway, and adjacent rooms such as a barber shop and kitchen.
At approximately half past noon, the deceased Clark and Woodward were seen seated at the window of the mess room, facing inward and conversing with Sergeant Hoey and witness Merritt, while others were in various positions (e.g., Barber shop, squad room, near the water tank).

Merritt observed the defendant entering through the passageway with a gun, raising it, and discharging it at Hoey, then extracting the cartridge and firing further.
Witnesses from the squad room, the barber shop, the water tank, and the billiard area testified on the number of shots fired, the movements of the defendant, and the position of the victims.
Testimonies established varied details regarding the number and sequence of shots, positions of victims, and the sounds and exclamations following the shooting.

Hoey’s death was instantaneous due to a gunshot that shattered his face.
Clark sustained two wounds (one piercing the abdomen and another the face), dying within three days.
Woodward was fatally shot through the hips, and Wilson sustained a wound in the left shoulder that led to his death.

The record shows that for weeks prior to the shooting, there had been tension between the defendant and Sergeant Hoey arising from repeated reprimands and allegations related to improper proposals made by the defendant, especially toward young males such as Edward T. Clark.
The defendant’s testimony revealed that he had been aggrieved by personal slights and public rebukes by Hoey and Wilson (whom he had been on friendly terms with previously), which escalated his resentment and indignation over time.
On the morning of May 11, 1908, at target practice, a dispute arose between the defendant and Hoey, and later, while passing by the mess room window, the defendant allegedly perceived a provocative gesture (a “made-up face”) by Hoey.
The defendant’s account of his state of mind indicates he reached a “limit” stemming from long-accumulated grievances, although this claim was undermined by contradictory testimonial evidence.

The defendant admitted to having had a prior dispute with Hoey and Wilson but tried to claim that his murderous act was a sudden, heat-of-the-moment reaction to an immediate provocation (the insulting gesture by Hoey).
His narrative detailed his movements: leaving the water-closet, retrieving his gun, and proceeding to the dining room with the intent to “kill Hoey and Wilson,” although later he attempted to minimize his intent regarding other victims such as Clark.
His later statements, including the exclamation “At last I have got two,” suggested satisfaction in executing a long-contemplated plan rather than an impulsive act driven solely by momentary passion.

Whether the killing was done with premeditation and deliberation, thereby qualifying the crime as murder with the aggravating circumstance of treachery and premeditation.
Determination of whether any present provocative act justified the shooting in the heat of passion, or if the true motive was long-standing malice and a desire for vengeance.

The reliability of the defendant’s account regarding the timing and cause (stated as a response to a “made-up face”) of his murderous intent.
The conflict between his testimony and that of multiple corroborative witnesses regarding the sequence of events and the positions of the victims at the time of the shooting.

Whether the imposed sentence should reflect the maximum penalty given the presence of a premeditated plan and the nature of the killings.
Consideration of the doctrinal and constitutional issues concerning the legal existence and jurisdiction of the courts in the Philippine Islands.