G.R. No. L-51368 - People vs. Macatanda

On October 11, 1902, the provincial fiscal of Antique filed a complaint charging twenty‐seven accused with the crime of double assassination under article 403 of the Penal Code.
The complaint detailed that on the night of April 14, 1902, with the pretext of buying aniseed wine, two principal defendants, Tomas Mamega and Ignacio Bundal, entered the residence of Marcos Buncag, the municipal president of Cagayancillo, while other conspirators waited outside.
Prior meetings were held as early as the preceding Thursday in Bundal’s storehouse in Jilaga where several defendants met to discuss their grievances against the president; subsequent meetings on Friday, Saturday, and Sunday consolidated their plans to kill Buncag on Monday night.
In these meetings, details including roles (e.g., who would administer the first blow, which companions would assist if resistance was encountered) and measures to prevent any escape were discussed and agreed upon.

At approximately 7 o’clock in the evening on April 14, 1902, Bundal and Mamega entered President Buncag’s house under a fabricated pretext.
As Buncag went to retrieve wine from the bodega, Tomas Mamega struck him with a bolo, inflicting a severe wound on his left cheek and jaw.
Following Buncag’s cry of “I am done for,” he fled to the street where he was further attacked by Santiago Madiong and others, resulting in numerous fatal wounds.
After the murder, the conspirators remained to guard the house until the following day when the body was transferred to the municipal building and publicly exposed.

In the course of events, the municipal secretary Ciriaco Garrion attempted to escape but was attacked by Ignacio Bundal, who inflicted a wound on his neck that led to Garrion’s death nine days later.
The vice-president, Francisco Magbanua, was charged as an accessory for having signed a false report and minutes claiming that unknown bandits had attacked the town, thereby concealing the actual facts.
Many of the accused actively participated not only in the assassination of President Buncag but also in subsequent intimidation and control of the town, including forcing townspeople to witness the display of the president’s mutilated corpse.

The conspiracy against President Buncag stemmed from longstanding grievances due to his oppressive rule, having held high office for nearly twenty years under both the Spanish and American regimes.
The accused, mostly inhabitants of the northern part of the island, were motivated by hatred, abuse, and illegal exactions suffered under Buncag’s administration.
Their collective intent was to eliminate what they deemed a tyrannical official, an act which the court later characterized as the product of sedition and uprising.

The trial was conducted based on testimonies from several witnesses—including Antonio Trinidad, Apolonia, Domingo, and Maxima Buncag—and the principal defendant Ignacio Bundal’s own admissions regarding the meetings and planning of the crime.
The evidence firmly established that not only was the murder premeditated, but the act was also performed collectively, thereby implicating all members of the conspiracy in the gravity of the offense.

Whether the violent death of President Marcos Buncag, committed under premeditated conditions and through concerted action, qualifies as an assassination under article 403 of the Penal Code.
Whether the attack’s use of treachery, deception, and the element of night—combined with prior meetings—constitutes the aggravating circumstance of evident premeditation.

The issue of whether all participants in the conspiracy should be held equally accountable, including those who did not physically strike the victim but provided assistance or conspired in the murder.
Whether the doctrine of shared or joint liability applies given the inseparable nature of the acts committed by the group.

Whether the crime, though politically motivated by longstanding grievances, falls within the scope of the amnesty proclaimed on July 4, 1902.
Whether the defendants’ actions, including those of the principal defendants and accessories, can be shielded by the political pardon or whether they constitute criminal acts beyond its ambit.

The proper treatment of the accessory involvement of Francisco Magbanua in falsifying reports to the provincial authorities and whether his punitive measure should be different from that imposed on the principal architects of the crime.
Whether the separate incident involving the murder of Ciriaco Garrion by Bundal should be tried and punished separately as it was explicitly set aside in the proceedings.

The weight to be given to the confessions of certain defendants versus the denials of others in determining the extent of individual culpability.
The interpretation of the participation of some defendants who admitted presence and those who actively conspired to create sufficient evidence for joint liability.