Title
People vs Punsalan
Case
G.R. No. 1431
Decision Date
Jan 27, 1904
Simon Punsalan stabbed Francisco Tizon to death during a civil case proceeding, convicted of murder with treachery, sentenced to life imprisonment.

Case Summary (G.R. No. 1431)

Facts of the Case

The incident occurred on May 9, 1903, during which the defendant attacked the victim with a knife while Don Francisco P. Tizon was accompanying a justice of the peace into an adjoining room. During this time, the defendant approached the victim from behind and inflicted multiple stab wounds, ultimately resulting in the victim's death. Witnesses corroborated the events, confirming the manner of the attack and the severity of the injuries sustained, totaling approximately fifteen stab wounds.

Charges and Initial Ruling

Simon Punsalan was charged with the crime of murder in the Court of First Instance of Pampanga. The trial concluded with the court finding the defendant guilty and imposing a sentence of cadena perpetua, which is a form of life imprisonment under the then-existing legal framework. Additionally, the court ordered the defendant to indemnify the heirs of the deceased with a sum of 2,000 pesos, prescribing subsidiary imprisonment in case of insolvency and bearing the costs of the suit.

Legal Findings

The lower court concluded that the qualifying circumstance of alevosia, or treachery, was present due to the execution of the crime. However, the court also considered aggravating factors such as premeditation and the location of the crime, which was near public authorities. Upon review, it was determined that the evidence did not sufficiently support claims of premeditation, nor was it established that the crime occurred in the presence of public authorities.

Final Decision

Considering the absence of aggravating

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