Facts:

• The case involves The United States vs. Cornelio Devela et al..
• Defendants: Cornelio Devela and Silvestre Absolio.
• Charged with robbery with homicide under clause No. 1, article 503 of the Penal Code.
• Incident date: September 22, 1903, near Sabang River.
• Victim: Luis Oleta, sent to deliver 500 pesos to a store in Mauban.
• Defendants approached Oleta armed with a bolo and a dagger, demanding money.
• Oleta resisted by throwing a stone at Absolio, leading to a violent confrontation.
• Defendants inflicted seven wounds on Oleta, six of which were fatal.
• Prosecution relied on defendants' statements during capture and Absolio's trial testimony.
• Absolio admitted intent to rob and that he struck the first blow.
• Trial court found defendants guilty, applying aggravating circumstances of alevosia and despoblado, sentencing them to death.
• The case was appealed, questioning the sufficiency of evidence for aggravating circumstances.

Issue:

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Ruling:

• The Supreme Court reversed the Court of First Instance's decision.
• Aggravating circumstances of alevosia and despoblado were not sufficiently proven.
• Defendants were convicted of robbery with homicide in its medium degree.
• Sentenced to life impr...(Unlock)

Ratio:

• For alevosia to be established, the crime must ensure the perpetrator's safety from potential victim defense.
• The attack was sudden and lacked premeditation; defendants did not secure their safety from Oleta's resistance.
• Oleta's act of throwing a stone indicated his capability to defend himself, negating alevosia.
• Insufficient evidence supported the claim of the crime occurring in an uninhabited place; no proof of nearby r...continue reading