Case Summary (G.R. No. 1255)
Factual Background
The facts reveal that Felipe Abaigar stabbed Constantino Nabaonag to death while Nabaonag was bound and unable to defend himself. The action committed by Abaigar was classified as murder, as it was established that he acted with alevosia, which is characterized by treachery or premeditation.
Initial Verdict
The lower court found Felipe Abaigar guilty of murder under Article 403 of the Penal Code, meting out the death penalty. The court based its decision on aggravating circumstances it identified, including deliberate premeditation, methods that heightened the humiliation associated with the crime, and the involvement of armed accomplices.
Examination of Premeditation
However, the appellate court disagreed with the lower court’s assessment of premeditation. The determination to kill Nabaonag was described by Abaigar as an immediate reaction to hearing derogatory remarks about himself, evidenced by his statement that upon hearing these comments, he was "furiously enraged" and acted instantly. This signifies that the intent to kill arose suddenly rather than being the result of a premeditated plan.
Ignominy and Aggravating Circumstances
The court also found that the circumstance of ignominy, which typically adds moral disgrace to the crime, was absent. The claim that Nabaonag was killed in the presence of his wife did not qualitatively enhance the humiliation or moral disgrace typically implied by ignominy. The death of Nabaonag ostensibly lacked any means or circumstances that would further disgrace him, particularly as there was no attempt to amplify the effects of the crime.
Absence of Armed Accomplices
Moreover, the evidence indicated that the crime was committed solely by Abaigar, without the aid of armed individuals. The mere presence of other armed individuals nearby did not contribute to an aggravating circumstance, as it was established that these individuals did not influence the commission of the crime nor participate in any related discussions leading up to the stabbing.
Conclusion and Sentence
In light of these conside
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Overview of the Case
- The case involves the appeal of Felipe Abaiqar, who was initially convicted of murder for the stabbing death of Constantino Nabaonag.
- The decision was rendered by the Supreme Court of the Philippines on August 17, 1903.
- The main legal issue revolves around the classification of the crime and the appropriate penalty.
Factual Background
- Felipe Abaiqar stabbed Constantino Nabaonag while the latter was bound and unable to defend himself.
- The act was described as an aggression against a defenseless individual, leading to the classification of the crime as murder under Article 403 of the Penal Code.
Court's Initial Findings
- The lower court found Abaiqar guilty of murder and imposed the death penalty.
- Aggravating circumstances were considered, including:
- Deliberate premeditation.
- Employment of means that added ignominy to the act.
- Commission of the crime with the assistance of armed men.
Reassessment of Premeditation
- The Supreme Court disagreed with the finding of premeditation