People v Siyoh

February 18, 1986

Petitioner: People of the Philippines
Respondent: Siyoh, Kiram, Indanan, Jamahali
Victims: de Castro, Hiolen, de Guzman (Anastacio), and de Guzman (Antonio)

Facts:
- On July 14, 1979, the respondents, being strangers to the victims, halted the latter’s pumpboat by
firing their firearms into the air. When boarded, they looted the ship’s merchandise and the
personal belongings of the victims, including their clothes.
- Upon looting the victims, the respondents then ordered the victims to jump into the water, when
they did, the respondents then fired their firearms at the victims who were then murdered; except
Antonio de Guzman, who was injured but survived.
- According to Antonio, he survived by hiding in a nearby mangrove and upon reaching nightfall, he
hitched a ride from a fishing boat. He was brought to the Philippine Army station at Maluso.
- The next day, while waiting for his friends dead bodies at the wharf, he spotted Siyoh and Kiram
who were apprehended
- Only Sihol and Kiram were apprehended, the other two could not be found.
Trial Court: Guilty beyond reasonable doubt of the Crime of Qualified Piracy with Triple Murder
and Frustrated Murder. Sentence: Supreme Penalty of death. 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 is recommended.
- INSTANT APPEAL
Issue:
- Whether or not Guilt has been proved beyond reasonable doubt.
Held:
- The defense of respondent that it was their missing companions who killed the victims does not
deserve merit; the Trial Court Judge stated that since the respondents conspired, they are equally
liable for the same crime.
- Even though the body of Anastacio de Guzman cannot be found and there is a chance that he is
alive, the number of deaths is irrelevant when being charged with the Special Complex Crime of
Qualified Piracy
- Affirm the Trial Court; modifying the Penalty to reclusion perpetua