G.R. No. 1271 - People vs Dasal

An information was filed on September 11, 1902, by the assistant prosecuting attorney of Manila, charging 35 persons with murder.
The crime occurred on or about August 13, 1902, on board the American steamer Dos Hermanos, of license No. 72, while the vessel was anchored near the town of Virac, Catanduanes Islands.
The prosecution’s basis for jurisdiction relied on the vessel’s registration and its presence in the navigable waters within the territorial limits of the Philippine Islands, thereby invoking provisions of national law on maritime offenses.

The Dos Hermanos was anchored with its bow toward shore and stern secured to the beach; supper had just ended when a mutiny broke out.
Key events on the evening of August 13, 1902:

Voices of a group of men were heard rushing from the bow of the ship, prompting Captain Morales, First Mate Zabala, and other officers to investigate.
The mutineers, including crew members armed with daggers, knives, and iron bars, initiated an organized assault on the ship’s officers.
The second engineer, Fabian Rendon, and Captain Morales were assaulted; Morales received multiple stab wounds (including to the groin and head), while Rendon sought refuge back in the pantry.
First Mate Zabala was attacked by several assailants, nearly thrown overboard, before escaping temporarily into the pantry with the captain and second engineer.

The first engineer, Antonio Agudo, was the first officer attacked; he was wounded in ten places by daggers, knives, and other deadly weapons and later found dead in his stateroom.
Other casualties included:

Vicente Amellategui, the steward, who was attacked with an iron hook and disappeared after jumping overboard.
Tan Chuen, the Chinese carpenter, who was also attacked and not seen again.
Wounding of Faustino Tremoya, a passenger, and other injuries inflicted on Captain Morales and First Mate Zabala.

Lowering side awnings, extinguishing lights, raising boats, cutting the stern cable, hauling up the accommodation ladder, raising the anchor with the donkey engine, and putting the vessel in motion—all to facilitate a swift escape.

First Lieutenant Fletcher of the Constabulary, stationed nearby, responded to the disturbance by boarding the vessel.
Despite the vessel’s movement, Fletcher and his men managed to board the ship by targeting the engine room and stern.
During the ensuing firefight and chase, several mutineers were either killed or captured; some jumped overboard and escaped.
Arrests were made of various crew members such as Vicente Gallardo, Ciriaco Silva, Gregorio Almondia, and others, while key figures like the quartermaster, Pantaleon Cajilig, evaded capture.

Testimonies from Captain Morales, First Mate Zabala, First Engineer Rendon, and various other crew members detailed the organized nature and premeditation of the mutiny.
Specific statements pointed to the involvement of Telesforo Dasal, among others, as a ringleader who used his position as helmsman to aid the mutiny.
The testimony of Lieutenant Fletcher provided corroboration of the violent acts and the attempted escape of the mutineers, as well as the sequence of events during the assault.

It was established that a significant portion of the crew conspired to commit acts of mutiny, organized attacks on the captain and officers, and ultimately the murder of First Engineer Agudo.
The crime was characterized by evident premeditation, deliberate planning, and the execution of coordinated actions to secure both the vessel and its wealth while evading legal consequences.

Whether the Court of First Instance in Manila had the exclusive jurisdiction over a crime committed on board a merchant steamer anchored in port.
The applicability of Act No. 400 and the modifications to the original organic law of the courts in determining proper venue.

Delineation of the roles of different crew members: distinguishing between those who actively participated in the mutiny and murder versus those merely present or hiding.
The evidentiary basis for holding specific defendants, such as Telesforo Dasal and Juan Briguela, as either principals or accomplices in the murder of Antonio Agudo.

Whether the murder of First Engineer Agudo, perpetrated in a premeditated and violent manner, qualifies for the aggravating circumstance of deliberate premeditation under article 403 of the Penal Code.
Consideration of aggravating circumstances such as abuse of superior power, nocturnity, and, in the case of Dasal, abuse of confidence.

The legal basis for imputing criminal responsibility to all members of the crew versus singling out those who demonstrated clear intent and direct participation.
Whether the acts of aid and protection of the principal offenders by other defendants should elevate their liability to that of principal offenders or render them merely accomplices.

Whether the circumstantial evidence presented was sufficient to convict certain defendants as co-principals in the murder.
The criteria to be applied in assessing indirect participation and the threshold for criminal complicity.