Name: Logarta, Hannah HNU College of Law

Subject: JD 402 [A] Criminal Law II J.D. 1

Case Name:

The People of the Philippines, plaintiff-appellee vs. Julaide Siyoh, Omar-Kayam

Kira, Namli Indanan, and Andaw Jamahali, respondents.

Supreme Court En Banc, Abad Santos, J.

G.R. No. L-57292
February 18, 1986

Doctrine: Article 123 - Qualified Piracy

The court emphasizes that P.D. No. 532 considers qualified piracy as a
special complex crime, regardless of the number of victims.

Facts: In Criminal Case No. 318, Julaide Siyoh and Omarkayam Kiram were
accused, along with two others, of qualified piracy, triple murder, and
frustrated murder. The incident occurred on July 14, 1979, in Mataja Is.,
Basilan, Philippines, where the accused, armed with firearms, stopped a
pumpboat, robbed its occupants, and ordered them to jump into the
water. The victims were shot, resulting in the deaths of Rodolfo de
Castro, Danilo Hiolen, and Anastacio de Guzman, while Antonio de
Guzman survived. Only Julaide Siyoh and Omarkayam Kiram were
arrested. After trial, they were found guilty and sentenced to death, but
due to their illiteracy and extreme poverty as members of cultural
minorities, the court recommended commutation to life imprisonment
under the provisions of Presidential Decree No. 532 and Section 106 of
the Code of Mindanao and Sulu.

Prosecution’s version:

Alberto Aurea, a businessman in Lamitan Public Market, Basilan,

supplied goods worth around P15,000 to Antonio de Guzman, Danilo
Hiolen, Rodolfo de Castro, and Anastacio de Guzman under an
agreement to sell the items and share the profits. However, the recipients
neither paid for nor returned the goods. On July 15, 1979, Antonio de
Guzman informed Aurea that his group had been held up near Baluk-
Baluk Island, resulting in the deaths of Rodolfo de Castro, Danilo Hiolen,
and Anastacio de Guzman.

The victims, along with Omarkayam Kiram and Julaide Siyoh, traveled to
various locations to sell the goods. On July 14, 1979, while returning to
Pilas Island on Kiram's pumpboat, they were intercepted by another
pumpboat with Kiram and Siyoh armed. The victims were robbed,
ordered to undress, and then Kiram and Siyoh fatally attacked Danilo
 Hiolen and Rodolfo de Castro. Antonio de Guzman managed to escape
by swimming and was later rescued by a fishing boat and brought to the
Philippine Army Station. The bodies of the deceased were found on July
16, 1979.

Antonio de Guzman identified Kiram and Siyoh as the perpetrators,

leading to their arrest. Kiram was even wearing pants taken from De
Guzman when apprehended. Medical examinations confirmed gunshot
wounds on Antonio de Guzman and fatalities for Rodolfo de Castro and
Danilo Hiolen. The prosecution presented these facts in a brief during the
trial.

Issue/s: Whether or not the court is correct in giving credence to the lone witness
of the prosecution.

Ruling: Yes, the court is correct. The trial court which had the opportunity of
observing the demeanor of the witnesses and how they testified assigned
credibility to the former and an examination of the record does not reveal
any fact or circumstance of weight and influence which was overlooked or
the significance of which was misinterpreted as would justify a reversal of
the trial court's determination. Additionally, the following claims of the
appellants are not convincing:

The defense argues that if Siyoh and Kiram were culprits, they could
have easily robbed victims at Kiram's house or during travels, asserting
that robbing at the house would raise suspicion, and robbing before
selling all goods would be premature. However, robbing and killing at sea,
after selling goods, was timely and concealed from prying eyes.

The defense argues that there is no evidence of Anastacio de Guzman's

death, as his remains were never recovered. However, the court
emphasizes that P.D. No. 532 considers qualified piracy as a special
complex crime, regardless of the number of victims, and Anastacio de
Guzman's missing status does not affect this.

The defense challenges the death certificates, claiming vagueness about

the nature of injuries sustained. The court points out that the cause of
death, "Hemorrhage due to hacked wounds, possible gunshot wounds,"
aligns with Antonio de Guzman's testimony that the victims were hacked
by Siyoh and Kiram with ‘barongs’ while Indanan and Jamahali were
armed with armalites.

Wherefore, finding the decision under review to be in accord with both the
facts and the law, it is affirmed with the following modifications: (a) for
lack of necessary votes the penalty imposed shall be reclusion perpetua,
and (b) each of the appellants shall pay in solidum to the heirs of each of
the deceased indemnity in the amount of P30,000.00. No special
pronouncement as to costs.