Case Summary (G.R. No. 6344)
Background and Incident
The appellants, identified as members of the second company of the Constabulary stationed in Davao, engaged in mutiny on June 6, 1909, during which they attempted to kill their superior, Lieutenant Goicuria. Following the mutiny, they left Davao, armed and with stolen ammunition, and planned to attack the town. On June 8, 1909, the group returned to Davao with the intent to assault it, leading to armed confrontation with local defenders, culminating in the death of Roy Libby and injuries to several residents.
Evidence and Findings
The court determined that the evidence presented overwhelmingly demonstrated the guilt of the appellants. Confessions from some defendants, testimonies from witnesses, and the corroborated accounts established clear participation in the mutiny and subsequent attack on Davao. Despite some appellants alleging coercion and intimidation from other mutineers, the court found no credible evidence to support this defense. The testimony suggested a unified assault on the town rather than an attempt to surrender, discrediting their claims.
Legal Considerations: Premeditation
The court examined whether the crime could be classified as murder based on premeditation conocida. The prosecution established that the appellants made a conscious decision to return to attack Davao after gathering information prior to the assault. The presence of premeditation was demonstrated by their actions, specifically their preparations and the decision to engage in violence, regardless of whether the specific victim, Roy Libby, was known to them.
Aggravating Circumstances
The trial court identified several aggravating circumstances but the appellate court undertook a detailed examination of each. It found that:
- Craft, Fraud, or Disguise: This was not present as the attack was overt and announced.
- Use of Superior Strength: The attackers did not demonstrate superior strength, given their eventual retreat.
- Abuse of Trust: There was no relationship of trust between the appellants and the Davao citizens.
- Use of Public Position: Appellants could not be said to have abused their position as Constabulary members during the crime.
- Exploitation of Calamity: The attack was not during a widespread calamity that would provide context for exploitation.
- Gang Attack: This was examined in conjunction with
Case Syllabus (G.R. No. 6344)
Case Overview
- The case involves an appeal by Manuel Rodriguez and several co-defendants against a conviction for murder, resulting in a death sentence handed down by the Court of First Instance of the Moro Province.
- The presiding judge was Hon. Herbert D. Gale, who found the defendants guilty of taking part in a mutiny that escalated into an attack on the town of Davao.
Background of the Incident
- The mutiny occurred on June 6, 1909, by members of the Constabulary stationed in Davao, during which they attempted to kill their superior officer, Lieutenant Goicuria.
- After the revolt, the mutineers took arms and retreated to the mountains of Lipada.
- On June 8, 1909, they returned to Davao with the intention of attacking the town, prompting the residents to prepare for defense.
The Attack
- Defenders of Davao, including J. L. Burchfield, P. C. Libby, A. M. Templeton, and Roy Libby, positioned themselves as an outpost to guard against the mutineers.
- At approximately 4:15 PM, the outpost engaged in a firefight with the mutineers, resulting in the death of Roy Libby and injuries to several others.
- The mutineers launched a concerted attack on various points of the town, particularly targeting the convent where many residents had gathered for safe