Title
People vs Dasal
Case
G.R. No. 1271
Decision Date
Dec 4, 1903
In 1902, a mutiny aboard the Philippine-registered *Dos Hermanos* led to the murder of the chief engineer. The Supreme Court ruled only specific crew members were guilty, citing premeditation and jurisdiction under Philippine law.

Case Summary (G.R. No. 1271)

Procedural Posture

An information for murder was filed in the Court of First Instance of Manila against thirty-five persons. The lower court convicted multiple defendants (death for three; life imprisonment for others) and acquitted or dismissed several. On appeal, the Supreme Court reviewed convictions, reclassified liability of many defendants (some acquitted, some convicted as principals or accomplices), adjusted penalties, and remanded for execution of judgment.

Jurisdictional Basis

The information alleged the crime occurred aboard a coasting merchant steamer within Philippine navigable waters and that the vessel later entered Manila. Under section 1 of Act No. 400 (modifying Act No. 136), a vessel of that description coming to Manila after the commission of the offense placed exclusive trial jurisdiction in the Court of First Instance of Manila; the appellate court accepted this basis for original trial jurisdiction.

Undisputed Factual Background

Shortly after 8:00 p.m. on August 13, 1902, while Dos Hermanos lay anchored near Virac, a sudden mutinous outbreak occurred among members of the crew. Multiple crewmen armed with knives, daggers, and iron bars attacked officers and others: First Engineer Antonio Agudo was assailed and later found dead in his stateroom with multiple wounds; the steward and a Chinese carpenter disappeared and were not recovered; Captain Miguel Morales, First Mate Juan Zabala, Second Engineer Fabian Rendon, and passenger Faustino Tremoya sustained injuries. During the outbreak mutineers extinguished lights, raised boats and ladder, cut the cable, raised anchor, started engines and attempted to sail away. The local Constabulary intervened; some mutineers were captured, some escaped, some were killed in the conflict.

Central Legal Issues on Appeal

  • Whether the killing of First Engineer Antonio Agudo constituted murder within the Penal Code (including whether qualifying circumstances existed).
  • Which defendants bore criminal responsibility and in what degree (coprincipals versus accomplices), given the varying degrees of participation and available evidence.
  • Whether particular aggravating or mitigating circumstances were present to affect punishment.
  • Whether some named defendants should be acquitted for lack of evidence.

Court’s Findings on the Nature of the Crime

The court found that the killing of Antonio Agudo was murder under article 403 of the Penal Code. The assault was carried out by several mutineers acting with evident premeditation and after concerted planning — the conspiracy to seize the vessel and kill officers made premeditation manifest. The crime’s commission in concert and by multiple assailants distinguished it as murder rather than a lesser homicide.

Principals, Accomplices and Standards of Criminal Liability

The court applied the Penal Code distinctions: principals (authors) versus accomplices (art. 13 and art. 14 as cited). It emphasized that not all crew members could be presumed co-principals simply by being aboard; specific evidence of participation (acts before, during, or facilitating the crime) or concerted agreement was required. Accomplice liability was found where there were acts of aid or protection, mediate or immediate, that furthered the principal offenders’ aims and where a common criminal agreement could be inferred from conduct.

Application of Evidence to Individual Defendants — Convictions

  • Telesforo Dasal: The court concluded Dasal was a coprincipal. Evidence showed prior conversation implicating him with the quartermaster and another in planning, and testimony placed him actively performing mutinous acts (attacking, pulling up ladders, ordering engines started). He was convicted as co-principal of murder.
  • Rufino de Jesus, Benigno Parra, Pablo Concepcion, Gregorio Almondia, Pedro Rodriguez, Emilio Lebiga: The court found sufficient circumstantial and testimonial evidence to convict these six as accomplices. Specific acts included moving about the deck during the mutiny, hauling up boats and the accommodation ladder (hindering boarding), and direct participation in assaults (Rufino de Jesus assaulted Mate Zabala). Their conduct was viewed as mediate aid and in accordance with the principals’ objective.

Application of Evidence to Individual Defendants — Acquittals and Dismissals

The court reversed convictions and acquitted a substantial number of defendants for lack of evidence, noting no direct or circumstantial proof they took part in the mutiny or killing. Carlos Septimo, Damaso Sopgang, and Jorge Orlano, though crew members, were found not to have participated. Several others named in the judgment likewise had no evidence connecting them to the crimes and were acquitted. Isidro del Valle, Tiburcio Soriano, and Exequiel Perez had died; the proceedings were dismissed as to them.

Treatment of Exculpatory Evidence and Burden of Proof

The court required proof of culpability for each defendant and rejected treating the entire crew as culpable simply because a subset conspired and acted. Where a defendant asserted compulsion or lack of participation (e.g., Juan Briguela claimed he started engines under threat), the majority ultimately concluded there was insufficient evidence to convict Briguela; one justice dissented, believing Briguela’s exculpatory claim unproven and that circumstantial evidence warranted conviction as an accomplice. The court emphasized that aggravating circumstances and qualifying elements (e.g., alevosia) must be established as clearly as the homicide itself and cannot be presumed.

Aggravating Circumstances Found

The court found the following aggravating circumstances applicable to the murder of Agudo:

  • Abuse of superior power (the victim was attacked by a number of assailants, preventing defense).
  • Nocturnity (the mutiny and murder occurred at night with the officers off-guard).
  • Abuse of confidence as to Telesforo Dasal, who, as helmsman, held a position of trust and used that position in plotting and executing the mutiny and murder.

No mitigating circumstances were identified.

Sentences and Civil Liability Imposed

  • Telesforo Dasal: Convicted as co-principal and sentenced to death; execution to be in the prison interior per article 101 of the Penal Code (the court recognized the offense predated Act No. 451). In the event of pardon, accessory penalties (absolute perpetual disqualification and subject to vigilance) would apply unless remitted with the principal penalty.
  • Benigno Parra, Pablo Concepcion, Gregorio Almondia, Pedro Rodriguez, Emilio Lebiga, Rufino de Jesus: Each convicted as accomplices and sentenced to seventeen years of cadena temporal, civil interdiction during the principal penalty period, and accessory penalties of absolute perpetual disqualif
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