G.R. No. 1431 - People vs Punsalan

The incident occurred on or about May 9, 1903, during the trial of a civil cause in the pueblo of Candaba, Province of Pampanga.
In the said civil case, Simon Punsalan was plaintiff and Don Francisco P. Tizon was defendant before the justice of the peace.
After completion of the trial testimonies, all witnesses were summoned to sign their statements in the office of the justice of the peace.

While one witness was in the process of signing his statement, the justice of the peace invited Don Francisco P. Tizon to accompany him into an adjoining room.
At that moment, Simon Punsalan, who was present in the same vicinity, suddenly arose armed with a penknife.
Punsalan followed Mr. Tizon into the adjoining room and began to stab him, primarily targeting the back and other parts of his body.
The stabbing resulted in approximately fifteen wounds of varying degrees of severity, which were all inflicted by the penknife.

The death of Mr. Tizon was directly attributed to the injuries caused by Punsalan’s actions.
Multiple witnesses testified to the events, substantiating that the victim, unarmed throughout the incident, was fatally attacked by a penknife-wielding defendant.
There was no evidence presented regarding a specific motive or provocation from the defendant that led to the attack.

Simon Punsalan was tried in the Court of First Instance of the Province of Pampanga where he was found guilty of murder.
The lower court found that the murder was qualified by the circumstance of alevosia—that is, treacherous or treasonable killing without the victim’s opportunity to defend himself.
Additionally, the court noted allegations of aggravating circumstances such as premeditation and the crime being committed in the presence of public authorities.
However, it was determined that there was no sufficient proof to sustain premeditation and the claim regarding the location of the crime.
Accordingly, under the provisions of article 97 of the Spanish Penal Code, the medium degree of penalty was deemed appropriate.
The sentence imposed was cadena perpetua (life imprisonment) along with accessory penalties under subsections 2 and 3 of article 54 of the Penal Code, indemnification of 2,000 pesos to the heirs of the deceased (with subsidiary imprisonment in case of insolvency), and payment of court costs.

Whether there was sufficient evidence to support aggravating circumstances such as premeditation.
Whether the location of the crime, purportedly among public authorities, could be substantiated as an aggravating factor.
Whether any extenuating circumstances were present to mitigate the defendant’s liability.

Whether the medium degree of penalty prescribed under article 97 of the Spanish Penal Code was appropriate given the absence of certain aggravating factors.
Whether the accessory penalties, including indemnification and subsidiary imprisonment, were properly imposed.