G.R. NO.

1255 August 17, 1903

THE UNITED STATES , COMPLAINANT- APPELLEE, VS FELIPE ABAIGAR, DEPENDANT-
APPELLANT,
Facts
Felipe Abaigar was accused of murdering Constantino Nabaonag. The evidence showed that Abaigar
stabbed Nabaonag to death while the latter was bound and unable to defend himself. This act was
classified as murder under Article 403 of the Penal Code due to the presence of alevosia (treachery).
Issues
The main issues in the case were:

1. Whether the crime was committed with premeditation.

2. Whether the crime involved ignominy (disgrace) and the assistance of armed men.

Ruling
The court found that:

 There was no premeditation as the decision to kill was made suddenly and executed immediately
upon hearing that the deceased had spoken ill of the defendant.
 The circumstance of ignominy was not present because the act did not involve any means or
circumstances that added disgrace to the crime.
 The crime was not committed with the assistance of armed men as the defendant acted alone,
despite the presence of armed men nearby who did not participate in the crime.

As a result, the court ruled that the appropriate penalty was life imprisonment instead of the death
penalty initially imposed by the lower court.
G.R. NO. L-16595 February 28, 1962

THE PEOPLE OF THE PHILIPPINES PLAINTIFF-APPELLEE, VS PRIMITIVO PINCA @ TIBOY, ET AL.,

DEFENDANTS, PRIMITIVO PINCA @ TIBOY & PASCUALITO ADORA @ LITOY, DEFENDANTS-
APPELLANTS.

The defendants were charged with Robbery in Band with Multiple Homicide and Serious Physical
Injuries.

Facts

 On October 18, 1958, at around 1:00 AM, the accused, armed with deadly weapons, forcibly
entered the house of Ambrosio Montallana in Sitio Cadahonan, Gamay, Samar.
 They attacked and killed Ambrosio Montallana, Donato Arceno, and Gregorio Ortiz, and seriously
injured Teodoro Montallana, a 10-year-old child.
 The accused also tied up Virginia Tan de Montallana, Ambrosio’s wife, and threatened her to
reveal the hiding place of their money.
 The accused stole cash and other valuables from the house.

Issues

The main issue was whether the defendants were guilty of the crimes charged, given their voluntary plea of
guilt.
Ruling

The Supreme Court affirmed the conviction of the defendants. The court found that the plea of guilt was
made voluntarily and with full understanding of its consequences.

The defendants were sentenced to reclusion perpetua (life imprisonment) for their crimes.
GR L-31402 AUGUST 17, 1981
PEOPLE OF THE PHILIPPINES AS THE PLAINTIFF-APPELLEE VS FELICIANO C.
HIPOLITO AND CIRILO MALAGAMBA AS DEFENDANTS

Facts

The victim was shot and mortally wounded while making a telephone call outside a small “tienda.” Feliciano
Hipolito admitted to killing the victim, and Cirilo Malagamba admitted his participation during a custodial
investigation in 1968, without the assistance of counsel.

Issues:

The main issues were the voluntariness of the extrajudicial confessions and the absence of counsel during
the custodial investigation.

Ruling

The Supreme Court ruled that the claim of maltreatment was not corroborated, and the right to counsel
during custodial investigation was applicable only after the enactment of the 1973 Constitution.

The Court affirmed the judgment, sentencing Hipolito to death and Malagamba to reclusion perpetua.
GR 130144 MAY 24, 2001

MELECIA PAÑA AND EMMANUEL TIGUMAN, PETITIONERS, VS JUDGE FLORIPINAS C. BUYSER,

PRESIDING JUDGE, BRANCH 30, RTC, THE PEOPLE OF THE PHILIPPINES AND THE HEIRS OF
JOSE JUANITE, SR. AND JOSE JUANITE, JR., RESPONDENTS

involves a case where Melecia Paña and Emmanuel Tiguman were convicted of murder and sentenced to
death by the trial court.

Facts

 On December 10, 1993, Jose Juanite, Sr. and his son, Jose Juanite, Jr., were shot and killed in
their home in San Pedro, Alegria, Surigao del Norte.
 The assailants were identified as Jose Bilboro Pomoy, Jr. (alias “Robert Bayan”), Emmanuel
Tiguman, and Melecia Paña.
 The prosecution alleged that Tiguman and Paña hired Pomoy to kill the victims due to a land
dispute.

Issues

 Whether the trial court committed grave abuse of discretion in convicting Tiguman and Paña.
 Whether the evidence presented was sufficient to support the conviction of Tiguman and Paña as
principals by direct participation and inducement, respectively.

Ruling

 The Supreme Court treated the petition for certiorari as an appeal due to the automatic review of
the death penalty.
 The Court found that the evidence was sufficient to convict Tiguman and Paña. The trial court’s
decision was upheld, affirming the conviction and the death penalty.
GR NO 93485 JUNE 27, 1994

People of the Philippines, PLAINTIFF-APPELLEE, VS Pedro Cedenio Y RASONABLE, Felipe

Antipolo Y MISA, and Jurito Amarga Y BAHI-AN, ACCUSED-APPELLANTS.

Facts:

On the night of November 26, 1986, the house of Hilario Dorio in Barangay Gandingan, Pangantucan,
Bukidnon, was set on fire. Witnesses saw the accused, Pedro Cedenio, Felipe Antipolo, and Jurito Amarga,
emerging from the burning house, wielding bolos. The fire resulted in the deaths of five members of the
Dorio family, including a 22-day-old infant

Issues:

The main issue was whether the accused were guilty of the crimes charged based on circumstantial
evidence, as no witness saw the actual killing or the setting of the fire

Ruling
The Supreme Court ruled that the guilt of the accused could be established through circumstantial
evidence. The Court found that the combination of circumstances, such as the presence of the accused at
the scene with blood-stained bolos and their flight from the burning house, sufficiently proved their guilt
beyond reasonable doubt. The accused were convicted and sentenced accordingly
GR 170470 SEPTEMBER 26, 2006

People of the Philippines vs. Edna Malngan y Mayo

Facts:
On January 2, 2001, a fire broke out at the residence of Roberto Separa, Sr. in Balut, Tondo, Manila,
resulting in the deaths of Roberto Separa, Sr., Virginia Separa, and their four children. Edna Malngan y
Mayo, the housemaid, was seen leaving the house hurriedly before the fire started. She was later
apprehended with a disposable lighter in her possession and allegedly confessed to setting the fire due to
unpaid wages and mistreatment.
Issues:

1. Whether the circumstantial evidence presented by the prosecution was sufficient to convict Edna
beyond reasonable doubt.
2. The admissibility of uncounselled confessions and hearsay as evidence.
3. The correct classification and penalty for the crime committed by Edna.

Ruling:
The Supreme Court affirmed Edna’s conviction. It ruled that:

1. The circumstantial evidence formed an unbroken chain leading to the conclusion of Edna’s guilt.
2. The uncounselled confession made to the Barangay Chairman was inadmissible, but the
confession made to a neighbor outside the custodial context was admissible.
3. Edna was guilty of simple arson under Presidential Decree No. 1613, as the primary intent was to
set fire to the house, not to kill the victims. The Court modified the penalty to reclusion perpetua
and adjusted the civil damages awarded.
GR 248372 AUGUST 27, 2020

People of the Philippines, PLAINTIFF-APPELLEE, VS Aubrey Enriquez Soria, ACCUSED-

APPELLANT.
Situation
Aubrey Enriquez Soria was charged with Qualified Arson under Presidential Decree No. 1613. The case
was brought to the Supreme Court after the Court of Appeals affirmed the Regional Trial Court’s decision,
which found Soria guilty.
Facts

 Incident: On February 22, 2012, a fire broke out in the house of Mariano Perez Parcon, Jr. in Cebu
City, resulting in the death of Cornelia O. Tagalog, a house helper.
 Accusation: Soria was accused of deliberately setting the house on fire.
 Evidence: Witnesses testified that Soria was seen fleeing the scene with a travel bag and a
shoulder bag. The fire caused significant damage to the house and the death of Tagalog.

Issues
The main issue was whether the circumstantial evidence presented was sufficient to prove beyond
reasonable doubt that Soria was responsible for the arson.
Ruling
The Supreme Court upheld the conviction, agreeing with the lower courts that the circumstantial evidence
was sufficient to establish Soria’s guilt beyond reasonable doubt. The Court found that the evidence
presented, including witness testimonies and the circumstances of Soria’s actions, supported the
conclusion that she was responsible for the fire.
GR 258187 OCTOBER 19, 2022
PEOPLE OF THE PHILIPPINESPLAINTIFF-APPELLEE, VS. RAYMUND CAMARSE Y GIMOTEA,
ACCUSED-APPELLANT
Facts:

 On July 19, 2011, Raymund Camarse and Regine Fernandez checked into a motel in Pasig City.
 Later that day, motel personnel noticed smoke coming from their room. Raymund ran out, shouting
that there was a fire and that his companion was still inside.
 Motel staff found Regine’s body with multiple stab wounds and evidence of arson. Raymund was
intercepted and brought to the police station, where a kitchen knife was found in his vehicle.
 The fire was determined to be intentionally set, with kerosene used as an accelerant.

Issues:

 Whether the circumstantial evidence presented was sufficient to convict Raymund Camarse of
murder and arson.

Ruling:

 The Supreme Court found Raymund Camarse guilty beyond reasonable doubt of murder and
destructive arson. He was sentenced to reclusion perpetua (life imprisonment) for the murder
charge.
GR 153559 JUNE 8, 2004
PEOPLE OF THE PHILIPPINES APPELLEE VS. ANTONIO COMADRE, GEORGE COMADRE AND
DANILO LOZANO, APPELLANTS.

Facts:

On August 6, 1995, in Barangay San Pedro, Lupao, Nueva Ecija, Antonio Comadre,
George Comadre, and Danilo Lozano were accused of throwing a hand grenade onto the
roof of Jaime Agbanlog’s house. The explosion resulted in the death of Robert Agbanlog
and injuries to several others, including Jerry Bullanday, Jimmy Wabe, Lorenzo Eugenio,
Rey Camat, Emelita Agbanlog, and Elena Agbanlog.

Issues:

1. Whether the accused were guilty of murder and multiple attempted murder.
2. Whether the use of explosives qualified the crime as murder under the Revised
Penal Code.

Ruling:

The court found Antonio Comadre, George Comadre, and Danilo Lozano guilty beyond
reasonable doubt of the complex crime of murder with multiple attempted murder. The
use of explosives was considered an aggravating circumstance 2.

Decision: The accused were sentenced to suffer the penalty of death for the murder of
Robert Agbanlog and the attempted murder of the other victims 12.
GR 210710 JULY 27, 2016
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE VS. LUISITO GABORNE Y CINCO ACCUSED-
APPELLANT
Facts:

 Incident Date: February 2, 2007

 Location: Barangay Mugdo, Hinabangan, Samar, Philippines
 Accused: Luisito Gaborne y Cinco, along with two others
 Victims: Sixto Elizan y Herrera and Rey Perfecto C. de Luna

Luisito Gaborne y Cinco and his co-accused were charged with the crimes of Murder with the use of an
Unlicensed Firearm and Frustrated Murder. On the night of the incident, the accused, conspiring
together, shot Sixto Elizan y Herrera with a .45 caliber pistol, causing his instantaneous death. They also
shot Rey Perfecto C. de Luna, inflicting serious injuries that could have resulted in death if not for timely
medical intervention1.
Issues:

1. Whether the accused is guilty of murder and frustrated murder.

2. Whether the use of an unlicensed firearm constitutes a special aggravating circumstance.

Ruling:

The Regional Trial Court (RTC) found Luisito Gaborne y Cinco guilty of both charges. This decision was
affirmed by the Court of Appeals (CA). The Supreme Court upheld the lower courts’ decisions, confirming
that the accused was guilty of Murder with the use of an Unlicensed Firearm and Frustrated Murder.
The use of an unlicensed firearm was considered a special aggravating circumstance under Republic Act
No. 82941.

Facts: On February 2, 2007, in Barangay Mugdo, Hinabangan, Samar, Luisito Gaborne,

along with two others, was accused of attacking Rey Perfecto De Luna and Sixto Elizan
at a videoke bar. The attack resulted in the death of Sixto Elizan and serious injuries to
Rey Perfecto De Luna. The accused were charged with Murder with the Use of
Unlicensed Firearm and Frustrated Murder12.

Issues:

1. The validity of Gaborne’s arrest and its effect on the jurisdiction of the trial court.
2. The merits of Gaborne’s defenses of denial and alibi.
3. The qualification of the crimes committed as Murder and Frustrated Murder
under the Revised Penal Code.
4. The reliability of eyewitness identification versus Gaborne’s defense.
5. The significance of the negative paraffin test results presented by Gaborne.
6. The appreciation of the unlicensed firearm use as an aggravating circumstance in
the crimes committed12.

Ruling: The Supreme Court upheld the decisions of the Regional Trial Court and the
Court of Appeals, finding Gaborne guilty of Murder with the use of an unlicensed firearm
and Frustrated Murder. The court dismissed Gaborne’s defenses of denial and alibi,
citing the positive identification by eyewitnesses. The use of an unlicensed firearm was
considered an aggravating circumstance12.
Decision: Luisito Gaborne was sentenced to reclusion perpetua for the murder and an
indeterminate sentence for the frustrated murder. The court also modified the damages
awarded to the victims12.
GR 17865 MARCH 15 1922
THE PEOPLE OF THE PHILIPPINES ISLAND, PLAINTIFF-APPELLEE, VS. CIPRIANA BUCSIT AND
PLACIDO LICUDINE, DEPENDANTS-APPELLANTS.

Summary:

In G.R. No. 17865, the Supreme Court of the Philippines dealt with a case involving
Cipriana Bucsit and Placido Licudine, who were accused of poisoning Pastor Pagaduan,
Cipriana’s husband.

Facts:

 Cipriana Bucsit and Placido Licudine were in an illicit relationship.

 They conspired to kill Cipriana’s husband, Pastor Pagaduan, by poisoning his
food.
 The poison was prepared by Placido and mixed into the food, which Pastor
Pagaduan consumed, leading to his death.
 The family dog also consumed the poisoned food and died.
 Both Cipriana and Placido confessed to the crime and pleaded guilty before the
justice of the peace.

Issue: The main issue was whether Cipriana Bucsit and Placido Licudine were guilty of
parricide and murder, respectively.

Ruling and Decision:

 Cipriana Bucsit was found guilty of parricide and sentenced to reclusion perpetua
(life imprisonment).
 Placido Licudine was found guilty of murder and sentenced to cadena perpetua
(perpetual imprisonment) due to the qualifying circumstance of poisoning 12.
GR 227504 JUNE 13, 2018

People of the Philippines, PLAINTIFF-APPELLEE, vs. Rodolfo Grabador, Jr., Roger Abierra, Dante
Abierra, and Alex Abierra, ACCUSED, ALEX ABIERRA, ACCUSED-APPELLANT,
Situation
The case revolves around the murder of Dennis Sumugat y Gequilapay on April 13, 2001, in Taguig, Metro
Manila. The accused were charged with murder, with the prosecution alleging that the crime was committed
with treachery and evident premeditation.
Facts

 Incident: On April 13, 2001, Dennis Sumugat was shot and killed with an improvised firearm by the
accused.
 Accusation: The accused were charged with murder, with the information stating that they
conspired and acted with intent to kill, using treachery and evident premeditation.
 Prosecution Evidence: Witnesses, including the victim’s brother, testified about the altercation
and subsequent shooting. The prosecution aimed to prove the elements of treachery and evident
premeditation.

Issues
The main issues in the case were:

1. Whether the killing was attended by treachery and evident premeditation.

2. Whether the prosecution provided sufficient evidence to convict the accused of murder.

Ruling
The Supreme Court affirmed the conviction of Alex Abierra for murder. The Court held that the prosecution
successfully proved the presence of treachery and evident premeditation. The sudden and unexpected
attack on the victim, as well as the deliberate planning and execution of the crime, were key factors in the
ruling1.
GR 223679 SEPTEMBER 27, 2017

People of the Philippines, PLAINTIFF-APPELLEE vs. WILFREDO LAYUG, NOEL BUAN AND
REYNALDO LANGIT, ACCUSED,

WILFREDO LAYUG AND NOEL BUAN, ACCUSED-APPELLANTS.

Facts:

 On June 1, 2001, Analiza Paule, a state witness, was at the plaza in Barangay
Luacan, Dinalupihan, Bataan, talking with Ramil Ambrosio about her supposed
“date” with the victim, Victorino Paule.
 Analiza later went to Wilfredo Layug’s house, where she, Wilfredo, and Noel Buan
had a shabu session. They then continued the session at Reynaldo Langit’s
house.
 During the session, Analiza overheard Reynaldo instructing Wilfredo and Noel
about a “hold-up.”
 Analiza met Victorino at the plaza, and they went to Benzi Lodge. After three
hours, they returned to the plaza.
 As they were walking, Noel held Victorino’s shoulder and stabbed him
twice. Wilfredo and Reynaldo helped Noel in stabbing Victorino 12.

Issue:

 Whether Wilfredo Layug and Noel Buan were guilty beyond reasonable doubt of
the crime of robbery with homicide.

Ruling and Decision:

 The Supreme Court affirmed with modification the decision of the Court of
Appeals, which upheld the Regional Trial Court’s decision finding Wilfredo Layug
and Noel Buan guilty beyond reasonable doubt of robbery with homicide 13.
GR 232339

People of the Philippines, PLAINTIFF-APPELLEE vs. Jefferson Maron y Emplona, Jonathan Almario
y Caygo, and Nestor Bulahan y Gutierrez, ACCUSED- APPELLANTS.
Summary:
This case involves the appeal of Jefferson Maron y Emplona, Jonathan Almario y Caygo,
and Nestor Bulahan y Gutierrez, who were convicted of murder by the Regional Trial
Court (RTC) of San Pablo City, Laguna. The Court of Appeals (CA) affirmed the conviction
with modifications.

Facts

 On January 4, 2010, Michael A. Clarianes was seated with Alma Exconde near Sampaloc Lake in
San Pablo City.
 Three men on a motorcycle arrived; two alighted and approached Michael and Alma.
 One man pointed a knife at Alma, while another pointed a knife at Michael.
 The men announced a holdup and demanded valuables.
 Michael resisted and was repeatedly stabbed by the three men, resulting in his death.
 Incident: On January 4, 2010, Michael Clarianes was stabbed to death by three
men, including the appellants, near Sampaloc Lake, San Pablo City.
 Prosecution’s Version: The prosecution presented evidence that the
appellants conspired to rob Michael and Alma Exconde. During the robbery,
Michael was repeatedly stabbed by the appellants, leading to his death.
 Defense’s Version: The appellants denied the accusations, claiming they were
not at the crime scene.


Issues
The primary issue was whether the appellants were guilty of murder with evident premeditation and treachery.
Ruling
The Supreme Court affirmed the conviction of the appellants for murder. The Court found that the prosecution had
proven beyond reasonable doubt that the appellants conspired to commit the crime with evident premeditation and
treachery, leading to the death of Michael A. Clarianes1.
Ruling:

The CA affirmed the RTC’s decision, finding the appellants guilty of murder. The
court ruled that the prosecution had sufficiently proven the elements of the crime,
including the presence of treachery and evident premeditation.
Summary:

This case involves the appeal of Jefferson Maron y Emplona, Jonathan Almario y
Caygo, and Nestor Bulahan y Gutierrez, who were convicted of murder by the
Regional Trial Court (RTC) of San Pablo City, Laguna. The Court of Appeals (CA)
affirmed the conviction with modifications.
Decision:

The appellants’ conviction was upheld, with the CA modifying the penalties and
damages awarded.
GR 148145-46 JULY 5, 2004

PEOPLE OF THE PHILIPPINES, APPELLEE VS. FELIX VENTURA Y QUINDOY AND ARANTE FLORES
Y VENTURA, APPELLANTS.
Facts:

 Date and Location: February 23, 2000, Bacolod City, Philippines.

 Accused: Felix Ventura and Arante Flores.
 Victims: Aileen Bocateja (deceased) and Jaime Bocateja (survived).
 Incident: The accused, armed with a .38 caliber homemade revolver and a bladed weapon,
attacked Aileen and Jaime Bocateja. Aileen succumbed to her injuries, while Jaime survived due to
timely medical intervention.

Issues:

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the aggravating circumstances of abuse of superior strength and use of an unlicensed
firearm were correctly considered.

Ruling:

 Trial Court: Found the accused guilty of Murder (for Aileen Bocateja) and Attempted Murder (for
Jaime Bocateja).
 Supreme Court: Affirmed the trial court’s decision, upholding the conviction of the accused for
Murder and Attempted Murder. The court also increased the award of exemplary damages from
PHP 20,000 to PHP 25,000 due to the presence of aggravating circumstances123.
GR 264913
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE VS. RONALD PARADERO APORADO,
ACCUSED-APPELLANT
Facts: Ronald Paradero Aporado was charged with murder for stabbing Amado B. Halasan. The incident
occurred in Bansalan, Davao del Sur, where Ronald, after being mocked and teased by a group including
Amado, went home and returned with a knife. He then stabbed Amado multiple times while Amado was
asleep, leading to Amado’s death1.
Issues:

1. Whether Ronald Paradero Aporado is guilty of murder under Article 248 of the Revised Penal
Code.
2. Whether the mitigating circumstances of sufficient provocation, passion and obfuscation, voluntary
surrender, and intoxication should be considered in Ronald’s favor.

Ruling: The court found Ronald Paradero Aporado guilty of murder. The mitigating circumstances
presented were not sufficient to reduce his criminal liability. The conviction was upheld by the Court of
Appeals1.
GR 244051 APRIL 28, 2021

People of the Philippines, PLAINTIFF-APPELLEE vs. Eduardo Canillo and Anthony Canillo,
ACCUSED-APPELANTS.
Situation
Eduardo Canillo and his son, Anthony Canillo, were charged with the murder of Alberto Bohol in Bayawan
City, Negros Oriental, on September 3, 2009.
Facts

 Incident: On the night of the incident, Alberto Bohol was driving a trisikad (a cycle rickshaw)
owned by Eduardo Canillo. A commotion was heard from Eduardo’s house, prompting a neighbor,
Eric Estrellanes, to look through a decorative hole in his wall.
 Eyewitness Account: Estrellanes saw Bohol running out of the house, followed by Eduardo and
Anthony, who were armed with bolos (machetes). They attacked Bohol, inflicting fatal injuries.
 Prosecution Evidence: The prosecution presented Estrellanes as an eyewitness and a medico-
legal officer who confirmed the cause of death.

Issues
The primary issue was whether Eduardo and Anthony Canillo were guilty of murder, considering the
elements of treachery, evident premeditation, and abuse of superior strength.
Ruling

 Trial Court: The Regional Trial Court convicted Eduardo and Anthony Canillo of murder, finding
that the attack was treacherous and premeditated.
 Court of Appeals: The conviction was upheld by the Court of Appeals.
 Supreme Court: The Supreme Court affirmed the decision of the lower courts, emphasizing that
the prosecution had sufficiently proven the elements of the crime, including treachery and evident
premeditation1.
GR 95891-92 FEBRUARY 28, 2000

People of the Philippines, PLAINTIFF-APPELLEE vs. Osmundo Fuertes @ “DODO”; AGUSTIN

LUYONG @ “JACK” AND “JACKIE PANGALAN” (AT LARGE): Edgar gibone; FRANCISCO SALVA @
“BOCHOY”; AND ROLANDO TAMO @ “BOY NEGRO” AND “BRANDO”, ACCUSED,

OSMUNDO FUERTES, ACCUSED- APPELLANT.

Situation
The case revolves around the brutal murder of two young boys, Napoleon Aldeguer (14 years old) and
Mateo Aldeguer (16 years old), who were killed for gathering firewood and coconuts from a hacienda
managed by Osmundo Fuertes.
Facts

 Date of Incident: November 1, 1986

 Location: Municipality of Mati, Province of Davao Oriental, Philippines
 Victims: Napoleon Aldeguer and Mateo Aldeguer
 Accused: Osmundo Fuertes, Agustin Luyong (at large), Edgar Gibone, Francisco Salva, and
Rolando Tano
 Crime: The victims were bound, gagged, brutally hacked to death, and their bodies were thrown
into a dried creek. The crime was committed with treachery, evident premeditation, and
aggravating circumstances such as abuse of superior strength, adding ignominy to the crime, and
committing the crime for a reward or promise12.

Issues
The main issues in the case were:

1. Whether the accused were guilty of the crime of murder.

2. Whether the aggravating circumstances were present and should affect the sentencing.

Ruling
The court found the accused guilty of murder. The presence of aggravating circumstances such as abuse
of superior strength, adding ignominy to the crime, and committing the crime for a reward or promise were
considered in the sentencing12.

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