Case Digest (G.R. No. 3621)
Facts:
The United States v. Macario Sakay, Julian Montalan, Leon Villafuerte, and Lucio de Vega, G.R. No. 3621, July 26, 1907, the Supreme Court, Johnson, J., writing for the Court; Arellano, C.J., Torres, Willard, and Tracey, JJ., concur.The United States prosecuted a number of accused—among them Macario Sakay, Julian Montalan, Leon Villafuerte, and Lucio de Vega—in the Court of First Instance of the Province of Cavite for the crime of bandolerismo (brigandage). The complaint charged that, during 1902–1906, the defendants organized and commanded armed bands of more than three persons, armed with deadly weapons, that committed robberies, detained persons for ransom, mutilated and killed inhabitants, and operated in Cavite, Batangas, Laguna, Rizal, and Bulacan. At arraignment on September 17, 1906, all pleaded not guilty.
During the trial the provincial prosecuting attorney moved under section 34 of General Orders No. 58 to dismiss the charges against Justiniano Ramos and Vicente Giron so they could serve as Government witnesses; the court granted the motion and discharged them. The prosecution also moved to transfer Francisco Carreon to the Court of First Instance of the City of Manila for lack of jurisdiction in Cavite; that motion was granted.
After presentation of testimony by twenty-one witnesses, on September 21, 1906, the defendants sought and were permitted to withdraw their not-guilty pleas and to plead guilty to the charged acts, in reliance on section 25 of General Orders No. 58 and the Court’s prior decision in United States v. Molo. Each defendant made a statement admitting the facts. The lower court nevertheless considered the evidence introduced prior to the guilty pleas, found the appellants guilty, and sentenced Macario Sakay, Julian Montalan, Leon Villafuerte, and Lucio de Vega to death; others received long terms of imprisonment.
The lower court made express findings that the accused, from 1902 until their surrender in 1906, organized armed bands that roamed and committed robberies, attacked pueblos to seize arms and municipal treasuries, detained and mutilated persons, and murdered municipal officials. The record contained documentary evidence (designated Exhibits J and N) consisting of letters signed by Macario Sakay ordering seizures of supplies and brutal punishments, which the court treated as demonstrating the character and purpose of the bands.
The appellants appealed to this Court assigning errors that (1) the lower court erred in considering evidence after the defendants pleaded guilty; (2) the court erred in failing to apply the mitigating circumstance in article 11 of the Penal Code; (3) the imposition of death violated paragraph 10 of section 5 of the Act of Congress of July 1, 1902 (the "Philippine Bill"); and (4) the death sentences were imposed without due process in violation of paragraph 1 of section 5 of the sa...(Pro-only)
Issues:
- Did the lower court err in considering the evidence introduced before the defendants changed their pleas from not guilty to guilty?
- Did the lower court err in refusing to consider the mitigating circumstance in Article 11 of the Penal Code?
- Did the imposition of the death penalty violate paragraph 10 of section 5 of the Act of Congress of July 1, 1902 (the Philippine Bill)?
- Were the defendants condemned without due process in violation of paragraph 1 of section 5 of the Philippine Bill?
- Should the defendants’ voluntary surrender, or the absence of a 24-hour period...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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