Title
People vs. Bundal
Case
G.R. No. 1312
Decision Date
Dec 21, 1903
Conspirators planned and executed the assassination of a local official, Marcos Buncag, and his secretary, Ciriaco Garrion, out of personal vengeance. The court ruled the crime was premeditated, involved treachery, and was not politically motivated, denying amnesty. Principals received life imprisonment; accomplices, 17 years. Francisco Magbanua acquitted due to duress.

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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