Case Digest (G.R. No. 5111)
Facts:
The United States v. Vicente Reyes and Severo Javier, G.R. No. 5111, August 18, 1909, the Supreme Court, Carson, J., wrote for the Court. The plaintiff and appellee was The United States; the defendants were Vicente Reyes and Severo Javier, and the appeal before the Court was prosecuted by Severo Javier alone.On or about August 21, 1908, in Manila, Reyes and Javier were charged with homicide for their roles in a nighttime, tumultuous affray in which the victim, Pedro Legaspi, was struck repeatedly on the head with a heavy wooden club and died of skull fractures and related injuries. The indictment alleged that Reyes and Javier "did then and there strike and beat the said Pedro Legaspi ... inflicting ... numerous deadly fractures of the skull" and that the assault caused Legaspi’s death. Both defendants were convicted by the trial court and each was sentenced to fourteen years, eight months, and one day of reclusion temporal, plus costs. No appeal was taken by or on behalf of Vicente Reyes.
The trial evidence was internally contradictory and marked by partisan testimony, but the trial judge made express findings of fact. The judge found that Javier and Legaspi were engaged in a quarrel and that Legaspi had a club (admitted as Exhibit A). Reyes, who came up to separate the fighters, was struck by the club, seized it, and delivered two mortal blows to Legaspi’s head. The trial judge further found that while Reyes was striking Legaspi, Javier was holding Legaspi so Reyes could inflict the wounds without substantial resistance, and that Reyes’ use of the club was unnecessary because the quarrel could have been stopped without weapons. Those findings supported conviction of Reyes but, on appeal by Javier alone, formed the basis for the Supreme Court’s review of Javier’s criminal liability.
The case reached the Supreme Court by appeal of Javier; his counsel argued that the evidence did not show concerted action or voluntary cooperation ...(Subscriber-Only)
Issues:
- Was appellant Severo Javier’s conviction for homicide supported by the evidence and thus properly affirmed?
- Did the evidence show such concerted action or reason to believe a deadly attack would be made that Javier could be held as a principal or accomplice under c...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)