People vs. Siyoh

People vs.
Siyoh
141 SCRA 356, G.R. No. L-57292, February 18, 1986
FACTS: On 14th day of July, 1979, in the Province of Basilan, Philippines, the above named accused,
being strangers and without lawful authority, armed with firearms and taking advantage of their
superior strength, conspiring and confederating together, aiding and assisting one with the other, with
intent to gain and by the use of violence or intimidation against persons and force upon things, did then
and there willfully, unlawfully and feloniously, fire their guns into the air and stop the pump boat
wherein Rodolfo de Castro, Danilo Hiolen, Anastacio de Guzman and Antonio de Guzman were riding,
traveling at that time from the island of Baluk-Baluk towards Pilas, boarded the said pump boat and
take, steal and carry away all their cash money, wrist watches, stereo sets, merchandise and other
personal belongings amounting to the total amount of P 18,342.00, Philippine Currency; that the said
accused, on the occasion of the crime herein above-described, taking advantage that the said victims
were at their mercy, did then and there willfully, unlawfully and feloniously, with intent to kill, ordered
them to jump into the water, whereupon, the said accused, fired their guns at them which caused the
death of Rodolfo de Castro, Danilo Hiolen, Anastacio de Guzman and wounding one Antonio de Guzman;
thus the accused have performed all the acts of execution which would have produced the crime of
Qualified Piracy with Quadruple Murder, but which, nevertheless, did not produce it by reasons of
causes in dependent of their will, that is, said Antonio de Guzman was able to swim to the shore and hid
himself, and due to the timely medical assistance rendered to said victim, Antonio de Guzman which
prevented his death. The Court found the accused Omar-kayam Kiram and Julaide Siyoh guilty beyond
reasonable doubt of the crime of Qualified Piracy with Triple Murder and Frustrated Murder as defined
and penalized under the provision of Presidential Decree No. 532, and hereby sentenced each one of
them to suffer the supreme penalty of death. From the evidences gathered, it also appeared that the
defendants were with the victims, helping them to sell the latter’s merchandise. However, considering
the provision of Section 106 of the Code of Mindanao and Sulu, the illiteracy or ignorance or extreme
poverty of the accused who are members of the cultural minorities, under a regime of so called
compassionate society, a commutation to life imprisonment was recommended.
ISSUE: Whether or not the defendants are guilty beyond reasonable doubt considering the credibility of
the witness Antonio de Guzman
HELD: Yes. Suffice it to say that robbing the victims at Kiram's house would make Kiram and his family
immediately suspect and robbing the victims before they had sold all their goods would be premature.
However, robbing and killing the victims while at sea and after they had sold all their goods was both
timely and provided safety from prying eyes. No evidence was presented and nothing can be inferred
from the evidence of the defense so far presented showing reason why the lone survivor should pervert
the truth or fabricate or manufacture such heinous crime as qualified piracy with triple murders and
frustrated murder? Despite the defendants’ contention that there is no evidence Anastacio de Guzman
was killed together with Rodolfo de Castro and Danilo Hiolen because his remains were never
recovered, there is no reason to suppose that Anastacio de Guzman is still alive or that he died in a
manner different from his companions. The incident took place on July 14, 1979 and when the trial court
decided the case on June 8, 1981 Anastacio de Guzman was still missing. But the number of persons
killed on the occasion of piracy is not material. P.D. No. 532 considers qualified piracy, i.e. rape, murder
or homicide is committed as a result or on the occasion of piracy, as a special complex crime punishable
by death regardless of the number of victims. The decision of the lower court was then affirmed with
modifications for lack of necessary votes the penalty imposed shall be reclusion perpetua.
RATIO: Qualified piracy is a special complex crime punishable by reclusion perpetua to death, regardless
of the number of the victims. The number of persons killed on the occasion of piracy is not material. P.D.
No. 532 considers qualified piracy, i.e. rape, murder or homicide is committed as a result or on the
occasion of piracy, as a special complex crime punishable by death regardless of the number of victims.
(Note: Qualified piracy is now punishable by reclusion perpetua to death.)

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