Case Digest (G.R. No. 1331)
Facts:
The case involves the complainant United States against defendants Melecio Macalintal and Isidoro Palad. This incident transpired on the night of September 12, 1902, when Isidoro Palad’s mother fell ill, leading him to suspect witchcraft was afoot. In a fit of rage, he struck his mother multiple times, during which she allegedly claimed that the witch was named Saturnina. Fueled by this belief, Palad searched for Saturnina Austria and forcibly abducted her from her home in Sibul, San Miguel, and dragged her to Batong-Uling. Once there, Palad and Macalintal inflicted gruesome injuries upon her, including cutting off both of her ears and ultimately causing her death by striking her head against a rock.
The prosecution commenced when Antonio Crespillo, the medical inspector, examined Saturnina's corpse three days after her burial at Batong-Uling and noted fractures, bruises, and mutilations. Witnesses, including Margarita Gumabun and Julia de Jesus, testified they observed Pa
Case Digest (G.R. No. 1331)
Facts:
On March 10 of the present year, an information was filed in the Court of First Instance of Bulacan charging Isidoro Palad and Melecio Macalintal with murder. It is alleged that on the night of September 12, 1902, Isidoro Palad, suspecting that his ailing mother’s sickness was due to witchcraft, acted upon the tip that Saturnina Austria was the alleged witch. Palad, along with Macalintal, forcibly abducted Saturnina from her residence in Sibul, San Miguel. They then subjected her to brutal treatment at Batong-Uling, which included cutting off her ears, kicking her head, and ultimately inflicting a head wound that led to her death. Eyewitnesses testified that they saw the accused submerging Saturnina in a river, while a medical inspector reported injuries such as a fractured skull and bruises consistent with a heavy blow. The accused, in their version, claimed that their actions were initiated in an attempt to compel Saturnina to cure the sick woman—motivated by their genuine, though erroneous, belief in the efficacy of witchcraft and incantations.Issues:
- Whether the acts committed by the accused, despite their evident brutality, constituted the crime of murder or, on the merits of their intentions and circumstances, should be deemed homicide.
- Whether the qualifying circumstance of cruelty was applicable, given that the accused acted under an impulse of passion and a mistaken belief in witchcraft.
- How the mitigating circumstances (impulse of passion and erroneous belief) and the aggravating circumstance (abuse of superiority) should be weighed in rendering the appropriate penalty.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)