### Facts:
In a series of events culminating on April 18, 1994, in Barangay Ambulong, Municipality of Magdiwang, Province of Romblon, Julio Recto y Robea was involved in violent confrontations that resulted in criminal charges against him. These confrontations happened against the backdrop of attempts by Recto and others to harvest fields following a court decision favorably to them, which led to tensions with the group of Linda Rance who employed Emiliano “Renato” Santos as a bodyguard. On the day of the incident, Barangay officials were addressing a separate issue of stolen palay when Recto and his group arrived, leading to armed confrontation.
This resulted in four separate Informations being filed against Recto: two counts of the complex crime of qualified direct assault with frustrated homicide (Criminal Case Nos. 1970 and 1971), one count of the complex crime of qualified direct assault with murder (Criminal Case No. 1972), and one count of homicide (Criminal Case No. 1973). During the arraignment, Recto, with legal representation, pleaded not guilty to all charges.
### Issues:
1. Whether the presence of qualifying circumstances of treachery was incorrectly appreciated in Criminal Case No. 1972 leading to a conviction of murder.
2. Whether the trial court erroneously found Recto guilty of direct assault resulting in convictions of complex crimes in Criminal Cases Nos. 1970 and 1972.
### Court’s Decision:
The Supreme Court modified the decision of the Regional Trial Court of Romblon:
1. **Criminal Case No. 1970:** Recto was convicted of attempted homicide instead of qualified direct assault with frustrated homicide.
2. **Criminal Case No. 1971:** Recto was convicted of the complex crime of qualified direct assault with attempted homicide instead of qualified direct assault with frustrated homicide.
3. **Criminal Case No. 1972:** Recto was convicted of qualified direct assault with homicide instead of the complex crime of qualified direct assault with murder, as the qualifying circumstance of treachery was not found.
4. **Criminal Case No. 1973:** Conviction for homicide was affirmed but penalty was modified.
### Doctrine:
– Treachery cannot be appreciated to qualify a killing to murder if the aggressor did not deliberately adopt a mode of attack intended to ensure the killing without risk to themselves.
– For a conviction of direct assault, it must be proven that the act was committed against persons in authority or their agents in the performance of their official duties, or on the occasion thereof.
### Class Notes:
– Definitions and distinctions between attempted, frustrated, and consummated stages of offenses are crucial to understand the degrees of liability and corresponding penalties.
– The concept of “people in authority” and their “agents” is fundamental in offenses involving direct assault.
– The qualifying circumstance of treachery (alevosía) requires a deliberate choice of method of execution that ensures the safety of the aggressor from any defensive or retaliatory act on the part of the victim.
– The Indeterminate Sentence Law applies in determining the appropriate range for penalties.
### Historical Background:
The violent confrontations of April 18, 1994, in Barangay Ambulong, Municipality of Magdiwang, Province of Romblon, were part of a larger conflict rooted in disputed land rights and court decisions affecting community relationships.
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