G.R. No. L-32562 - People vs. Cristobal, Jr. y Sarmiento

On December 23, 1969, at about 1:00 a.m., a hold-up occurred inside a passenger jeepney on its route from Malabon to Sta. Cruz via Rizal Avenue.
The jeepney, operated by driver Melquiades San Jose, was carrying several passengers including Dominador Villanueva, a special police officer of the Bureau of Customs, and Mario Fernandez.
Four accused persons were involved: Aurelio Cristobal, Jr., Vicente Duncil, Florentino Valerio, Jr., and Canuto Pagaduan, with the latter later withdrawing his plea in one of the charges.

After boarding the jeepney near the Venus Hotel on Rizal Avenue Extension, the accused and some passengers took their seats in a manner that later became significant in identifying roles during the crime.
As the jeepney passed the intersection of Aurora Blvd. and Rizal Avenue Extension, a commotion began when Villanueva shifted from one seat to another.
Witness Mario Fernandez observed that while a hand snatched Villanueva’s wrist watch, Cristobal pulled out a knife from Villanueva’s lower body area, and subsequently, Fernandez himself was stabbed on the chest.
Concurrent with these actions, Pagaduan was seen grabbing a watch, which he later discarded as they all fled from the scene.

The testimony of Mario Fernandez provided detailed narration about the seating arrangement and the actions during the robbery, including the sequence of a hand reaching out to snatch the watch and the simultaneous stabbing.
Melquiades San Jose, the jeepney driver, corroborated the essential details such as noting Valerio’s suspicious actions near the front seat, his leaning outside, and later, the abrupt exit of the accused after witnessing the commotion.
The recovered watches (a Seiko and an Omega) became key pieces of evidence; the Seiko watch, found in Cristobal’s possession, was identified as belonging to Villanueva, while the Omega watch recovered from Pagaduan was linked to another passenger.
Subsequent police investigation led to the arrest of the accused, with further incriminating statements recorded from each suspect during the investigation.
The accused gave confessions – either voluntarily or under disputed circumstances – that provided details such as the sequence of boarding, their roles in the robbery, and specifics regarding the snatched watches and the use of a knife.

After the incident, a security guard at the Jose R. Reyes Memorial Hospital reported the event, prompting Patrolmen Cesar Arsaga, Rolando Macabejo, and R. Casupanan to investigate on Rizal Avenue Extension and nearby streets.
During the apprehension, witness identifications, frisking, and subsequent testimonies from suspects (including their statements on the note of a drinking session the previous night and the boarding of the jeepney) helped build the circumstantial evidence against them.
The investigation established a conspiracy among the accused as they were seen together before, during, and after the robbery, with evidence such as their seating arrangement and the fact that all were members of the “Sigue-Sigue Sputnik” gang, identified by matching tattoo marks.

Whether the Seiko watch recovered from Cristobal could be conclusively identified as the watch taken from the deceased Villanueva.
Whether the testimony regarding the snatching of Villanueva’s watch, particularly the identification of the hand of Duncil, was supported by sufficient evidence.

Whether the confessions (as shown in Exhibits F, G, and H) given by Cristobal, Duncil, and Valerio were voluntary or obtained through coercion.
The impact of any inconsistencies in the statements regarding their participation in the robbery and homicide.

Whether the trial Court correctly found aggravating circumstances such as nighttime, abuse of superior strength, and craft in the commission of the offense despite arguments by the accused.
Whether the nature of the setting—well-lighted jeepney and the timing after a drinking session—negates or diminishes the application of the aggravating factor of “nocturnidad.”

Whether the principle that “the act of one is the act of all” applies, thus holding all conspirators liable even if not all directly executed every element of the crime.
Whether the participation in the overall act of robbery with homicide, as evidenced by coordinated movements and actions, legally implicates all accused irrespective of individual roles during the crime.

The extent to which conflicting or incongruent details (e.g., the exact body part that was stabbed, and the order in which accused were brought to the hospital) affect the overall credibility of eyewitness accounts.
Whether the mistakes in witness recollections substantially undermine the evidence presented against the accused.