Case Digest (G.R. No. 5292)
Facts:
United States v. Moro Manalinde, G.R. No. 5292, August 28, 1909, the Supreme Court En Banc, Torres, J., writing for the Court.
Between 2 and 3 p.m. on January 19, 1909, in Cotabato, Moro Province, the accused Moro Manalinde unexpectedly attacked two persons with a kris. He struck Juan Igual, a Spaniard seated in a store doorway, wounding him; immediately afterward he attacked a Chinese laborer named Choa, cutting him in the left shoulder. Choa was taken to the hospital and died within an hour; the record does not state Igual's ultimate condition. The assailant fled the town carrying his weapon concealed in banana leaves.
The provincial fiscal filed a complaint for murder in the district court. At his arrest Manalinde pleaded guilty and confessed that he had acted “juramentado” by order of Datto Rajamudah Mupuck, who promised him a woman as reward and instructed him to blame other datus if captured. The trial judge found Manalinde the sole author, convicted him of murder on February 5, 1909, and sentenced him to death, ordered indemnity of P1,000 to the heirs of the deceased, and imposed costs. The case was submitted to the Supreme Court for review.
On review the Court examined whether the facts established murder and the presence of qualifying and aggravating circumstances (treachery, promise of reward, premeditation), whether obedience to the datto excused liability, and whether mitigating circumstances existed; the Court a...(Subscriber-Only)
Issues:
- Did the killing of Choa constitute murder within the meaning of Article 403 of the Penal Code?
- Were the qualifying and aggravating circumstances—specifically treachery (alevosia), promise of reward, and premeditation—present so as to sustain the imposed penalty?
- Does the accused’s claim that he acted under orders of Datto Mupuck (went juramentado) excuse or mitig...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)