PEOPLE

VS
SIYOH

TOPIC: QUALIFIED PIRACY IS A SPECIAL COMPLEX CRIME

(ART. 123 OF THE RPC)

Case doctrine: 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.

 Antonio De Guzman and his friends were merchants.

 They went to Pilas Island, Sangbay and Baluk- baluk to sell
goods.
 Together with them in selling goods were Siyoh and Kiram.
 After selling goods in Baluk- baluk, they went back to Pilas
Island.
 While travelling to Pilas through a pumpboat, another pumpboat
approached theirs, then, suddenly fired two shots.
 Kiram turned off the engine of the pumpboat of de guzman,
then, through a rope, they were towed by the other pumpboat
towards mataja island.
 On their way to mataja Island, the merchants were divested of
their money and goods, then undressed them.
 While everybody were undressed, Siyoh hacked Danilo Hiolen,
while Kiram hacked De Castro.
 Antonio De Guzman was able to jump into the water then swam
towards a mangrove.
 Thereafter, he stayed their till nightfall, where upon leaving the
mangrove, he saw the body of his 3 companions.
 Siyoh and Kiram were apprehended a day later.
 The trial 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 sentences each one of them to suffer the supreme
penalty of death.
 One of the contentions of the appellants was that their guilt was
not proven beyond reasonable doubt because the prosecution
did not present evidence that the accused were also the one who
killed Anastacio de Guzman because his remains were never
recovered.

ISSUE: W/N SIYOH AND KIRAM ARE GUILTY BEYOND REASONABLE

DOUBT FOR THE CRIME OF QUALIFED PIRACY WITH TRIPLE
MURDERS AND FRUSTRATED MURDER..

RULING: YES.
The SC ruled that 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.

Additional notes:
Other contentions of the appellants:
1. That if they were the culprits they could have easily robbed their
victims at the Kiram house or on any of the occasions when they
were travelling together.

SC ruling:  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.

2. The Credibility of the Witness—since only 1 witness was

presented.

SC: 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

3. That the accused immediately reported the incident to the PC in

Isabela.
SC: They claimed to be members of retrieving team for the dead
bodies but no PC soldiers were ever presented to attest this fact.

4. Appellants claim (Siyoh and Kiram) that they were not the
assailants but also the victim

SC: Appellants claim that they were not the assailants but also the
victim and that the two persons they have identified (Namli Indanan
and Andaw Jamahali) is baseless as view in the proven conspiracy
among the accused. The Conspiracy was established through the
testimony of the lone witness and survivor- De Guzman"