G.R. No. L-12822; February 25, 1918

FACTS:
The defendant-appellant, Narciso A. Siblag, was convicted of homicide in the trial court. The prosecution’s evidence, as credited by the trial judge, established his guilt. The evidence further revealed that the victim sustained multiple fatal wounds, including a hack to the throat that nearly severed it from the body. The prosecution, through the Acting Attorney-General, argued on appeal that the trial court erred in not finding the aggravating circumstance of ensañamiento (cruelty) due to the nature and number of wounds inflicted.

ISSUE:
Whether the trial court erred in not appreciating the aggravating circumstance of ensañamiento (deliberately and inhumanly increasing the victim’s suffering) based on the multiple fatal wounds found on the victim’s body.

RULING:
The Supreme Court affirmed the judgment of conviction. The Court upheld the trial judge’s findings on the credibility of the prosecution witnesses, finding no reason to disturb them. Regarding the issue of ensañamiento, the Court ruled that the trial court did not err. Citing its precedent in United States vs. Palermo (31 Phil. Rep., 425), the Court held that the mere number and gravity of wounds, without more, are not conclusive proof of the specific intent to deliberately and inhumanly increase the victim’s suffering. Such wounds may have been inflicted merely to ensure death, not to prolong agony. Since the evidence only showed the nature of the wounds and not the exact circumstances of their infliction, the aggravating circumstance of ensañamiento could not be validly appreciated. The judgment of the lower court was affirmed in all respects.

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