Title
People vs. Mercoleta
Case
G.R. No. 6073
Decision Date
Nov 15, 1910
Accused Catalino Mercoleta killed Go-Siaco with a bolo, claiming self-defense over unpaid debt. Convicted of murder, penalty reduced to life imprisonment due to treachery and premeditation.

Case Summary (G.R. No. 6073)

Facts of the Case

The prosecution's complaint alleged that Mercoleta maliciously attacked Go-Siaco with a bolo, inflicting a wound that almost decapitated the victim, resulting in immediate death. Mercoleta admitted to killing Go-Siaco but asserted self-defense. He claimed that prior to the attack, he had lent the victim a certain quantity of hemp and was cheated on its weight, leading to animosity. On the day of the incident, he encountered the victim, who allegedly brandished a penknife, which prompted Mercoleta to strike first.

Key Testimonies

Several witnesses provided testimony regarding the incident. Basilio Riel stated he heard cries and saw Go-Siaco fall shortly after he noticed the two men walking. Meanwhile, Zacarias Villarino, the bolo's owner, testified that Mercoleta borrowed the weapon without his permission, returning it later stained with blood. Mercoleta's left-handedness was noted, undermining his claim of self-defense as the fatal wound was inflicted on the left side of Go-Siaco's neck.

Preliminary Investigation and Confession

Mercoleta was arrested and later confessed to an auxiliary justice during a preliminary investigation. He detailed his actions leading up to the murder, indicating premeditation and intent to kill. However, during the trial, he denied making these statements. Testimonies from the auxiliary justice and a Constabulary lieutenant corroborated the confession, emphasizing that it was made freely and voluntarily.

Legal Analysis and Findings

The court identified the following elements: The attack was premeditated, marked by Mercoleta's deliberate preparation and concealment before the attack. The use of a bolo and the method of attack—striking from behind—indicated treachery and a lack of risk to the perpetrator, qualifying the act as murder under the law. While premeditation was established, the court found insufficient evidence to suppor

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