Case Summary (G.R. No. 172302)
Charges Filed
On October 11, 1902, the provincial fiscal of Antique filed a complaint in the Court of First Instance, charging the accused with double assassination under Article 403 of the Penal Code. The complaint alleges that Bundal and Mamega, under the pretense of purchasing aniseed wine, lured President Buncag into a trap where he was subsequently attacked by multiple assailants.
Sequence of Events
At 7:00 PM on April 14, Bundal and Mamega approached Buncag in his home, leading to a violent confrontation. Buncag was severely injured by Mamega's bolo strike, prompting a subsequent attack by Santiago Madiong and others until Buncag was incapacitated. During the chaos, another victim, Ciriaco Garrion, was also wounded by Bundal, resulting in Garrion’s death nine days later.
Conspiracy Details
Evidence reveals that Bundal orchestrated multiple meetings with accomplices prior to the assassination, where they discussed their grievances against Buncag and plotted the murder. They agreed on a plan to kill Buncag, demonstrating evident premeditation in the orchestration of their actions.
Testimonies and Evidence
Witnesses testified regarding the conspiracy and execution of the crime, including accounts of other defendants who were present during the commission of the offenses. Flight patterns and the response of the victims' families further illuminated the fear and intimidation exercised by the accused following the assassinations.
Judicial Proceedings and Verdict
After a thorough trial, the court found sufficient evidence to conclude that the violent death of Buncag constituted assassination, characterized by premeditation. Consequently, Bundal, Mamega, Madiong, and Conde were sentenced to death as principals, while the other conspirators faced lengthy prison sentences.
Acquitted and Accessory Sentences
The court acquitted ten additional defendants due to insufficient evidence of direct involvement. Francisco Magbanua, the vice-president, was found not criminally liable for acting under duress when he inadvertently contributed to misleading reports about the assassination. The court noted that he acted out of fear imposed by Bundal and his followers.
Consideration of Political Implications
The court explicitly ruled that the murders, while politically charged due to the nature of Buncag's prolonged leadership and local grievances, did not qualify for amnesty conferred by the July 4, 1902 proclamation. The court distinguis
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Case Overview
- The case centers around a complaint filed by the provincial fiscal of Antique against twenty-seven individuals charged with double assassination, specifically referencing the murder of Marcos Buncag, the municipal president of Cagayancillo, and the serious injury leading to the death of Ciriaco Garrion.
- The incident occurred on April 14, 1902, and involved a conspiracy among the accused to kill Buncag under the pretext of purchasing wine.
Background of the Incident
- On the night of the crime, Tomas Mamega and Ignacio Bundal entered Buncag's house, while others remained outside, positioned to assist in the assault.
- Buncag was attacked as he attempted to serve wine to the conspirators, leading to a violent confrontation that resulted in multiple stab wounds and his eventual death in the street.
- Ciriaco Garrion, the municipal secretary, was also attacked by Bundal as he attempted to escape, suffering a severe wound that caused his death nine days later.
Conspiracy and Planning
- Evidence revealed that Bundal convened several meetings in the days leading up to the murder to strategize the assassination of Buncag, driven by grievances against his long-term governance.
- The conspirators agreed on their roles, with premeditated plans to attack Buncag and prevent any resistance from his family or supporters.