Case Summary (G.R. No. 1331)
Charges and Facts
On March 10, 1903, the provincial fiscal filed an information against Palad and Macalintal, accusing them of murder. The facts of the case indicate that Palad, believing his mother was bewitched and suffering from ailments caused by Austria, physically attacked her. Palad and Macalintal's actions escalated to the point where they cut off Austria’s ears, submerged her in a river, and caused fatal injuries that led to her death. Witnesses testified to seeing the accused engaging in this violent act, with underlying motives attributed to the belief in witchcraft.
Examination of Evidence
Medical inspector Antonio Crespillo conducted an autopsy on Austria's body and provided testimony detailing the injuries sustained, including a skull fracture and multiple bruises. The defense, however, portrayed a different narrative, claiming that their actions stemmed from a desperate attempt to seek help for Palad’s sick mother. They argued that the injury to Austria’s ear was accidental, and aimed to compel her to provide a cure for the ailments attributed to her alleged witchcraft.
Court's Findings on Intent
The court found that while Palad and Macalintal had inflicted serious harm upon Austria, their actions did not constitute murder but rather homicide. The rationale was that their intent did not reflect malice aforethought or deliberate cruelty, as they were acting under the mistaken belief arising from ignorance about witchcraft and a misguided notion of coercing a cure. The court noted that such beliefs were prevalent in rural areas during the time.
Mitigating and Aggravating Circumstances
The court considered several factors in its determination. Mitigating circumstances were recognized, including the defendants acting under passionate impulse and the belief that their actions were justified by the circumstances surrounding the illness of Palad's mother. However, these were partially offset by the aggravating circumstance of abuse of superiority, as the defendants used their physical advantage against an unarmed victim.
Conclusion and Sentenc
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Case Background
- The case involves the prosecution of Isidoro Palad and Melecio Macalintal for the crime of murder.
- The incident occurred on the night of September 12, 1902, following the illness of Maria Estevan, the mother of Isidoro Palad.
- Palad suspected that his mother's illness was due to witchcraft allegedly perpetrated by Saturnina Austria, whom he later assaulted.
Circumstances of the Crime
- Isidoro Palad, believing that his mother was bewitched, confronted Saturnina Austria and accused her.
- Palad and Macalintal forcibly brought Saturnina to a location known as Batong-Uling, where they inflicted severe physical harm on her.
- The assault included cutting off both of her ears and violently submerging her in the river, ultimately leading to her death.
Evidence Presented
- Antonio Crespillo, a medical inspector, examined Saturnina's body after it had been buried for three days, finding evidence of severe trauma.
- Witnesses including Andres Castro, Margarita Gumabun, and Julia de Jesus testified