Case Digest (G.R. No. L-8922-24) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case of The People of the Philippines vs. Florentino Enguero, Jose Tariman, Nazario Narvarte, and Dionisio Bueno pertains to a robbery in band involving multiple defendants. The crime occurred on July 9, 1952, in Lupi, Camarines Sur. The four defendants were jointly indicted through three separate informations filed in the Court of First Instance of Camarines Sur, culminating in a trial that found them guilty as charged. Each was sentenced to varying terms of imprisonment: Florentino Enguero received an indeterminate penalty ranging from 8 years and 21 days of prision mayor to 14 years, 10 months, and 21 days of reclusion temporal for each criminal case. The other three defendants each received sentences ranging from 4 years and 2 months of prision correctional to 8 years and 21 days of prision mayor. They were also ordered to pay indemnities to the victims: Florentina Ogarte de Binaday, Cresenciano Magistrado, Juan Margate, and Anatolia Bragais.
The trial court detailed th
Case Digest (G.R. No. L-8922-24) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Overview of the Case
- The case involves the People of the Philippines as plaintiff and appellee versus four accused: Florentino Enguero, Jose Tariman, Nazario Narvarte, and Dionisio Bueno.
- The accused were charged with the crime of robbery in band in three separate informations and subsequently convicted by the Court of First Instance of Camarines Sur.
- The trial court rendered three distinct judgments (Criminal Cases Nos. 2714, 2715, and 2716), each with specific penalties and orders for indemnification and restitution.
- Details of the Convictions and Sentences
- In Criminal Case No. 2714:
- Florentino Enguero was sentenced to suffer an indeterminate penalty of no less than 8 years and 21 days of prision mayor and no more than 14 years, 10 months, and 21 days of reclusion temporal.
- Jose Tariman, Nazario Narvarte, and Dionisio Bueno were sentenced to suffer an indeterminate penalty of no less than 4 years and 2 months of prision correctional and no more than 8 years and 21 days of prision mayor.
- All defendants were ordered to indemnify Florentina Ogarte de Binaday in the amount of P36.75 and to pay the costs.
- In Criminal Case No. 2715:
- A similar sentence was imposed on Florentino Enguero as in Case No. 2714.
- The other three defendants received penalties similar to those in Case No. 2714.
- Additionally, they were ordered to indemnify Cresenciano Magistrado and Juan Margarte for amounts of P38.88 and P17.80 respectively, along with the payment of costs.
- In Criminal Case No. 2716:
- The sentence for Enguero mirrored those in the previous cases.
- Tariman, Narvarte, and Bueno were similarly sentenced as in the prior cases.
- They were ordered to indemnify Anatolia Bragais in the amount of P3 and to pay the costs.
- The judgments specified that in the event of insolvency, the appellant would not suffer subsidiary imprisonment in relation to the principal penalty.
- Several items used or carried during the robberies were either returned to their rightful owners or confiscated, including weapons and various personal articles (e.g., suit, shoes, raincoat, flashlight, pistol, and other personal effects).
- Chronology and Execution of the Robberies
- On July 9, 1952, at about 3:00 p.m., the four defendants met at Yabo River, Lupi, Camarines Sur, where Enguero, already armed with a pistol, assembled his accomplices.
- They proceeded to Enguero’s house for a meal at which weapons were distributed:
- Enguero retained the pistol.
- Jose Tariman received a balisong.
- Nazario Narvarte was given a bolo.
- Dionisio Bueno received a piece of hardwood.
- At around 7:00 p.m., they set off to Jaloban, Pigbasagan, Lupi, with stops that resulted in further acts of robbery:
- First at the house of Teodulo Banta, where guides were compelled under threat to lead them forward.
- They encountered and subdued additional persons (Pedro Bragais and Ernesto Belgado), binding their hands.
- Arrival at Cresenciano Magistrado's store at about 8:00 p.m. led to:
- Forcing the victims (including Magistrado and his wife) to surrender money and other valuables.
- The theft involved both cash and various articles such as Coca-Cola bottles, sardines, wine, earrings, pomade, and other grocery and personal items.
- Subsequent Stages of the Robbery:
- Later, the group proceeded to the house of Victorino Togno:
- Enguero, Tariman, and an initially co-accused, Clementino Carulla, looted items including a pair of shoes, a jacket, blue pants, and a hammer, extracting P3 in cash and goods totaling P45.
- Finally, at the house of Florentina Ogarte:
- Despite her protestations of having no money or jewels, Enguero conducted a search and engaged in indecent contact before resorting to looting merchandise from her store.
- After the robberies, the offenders regrouped, transferred the stolen goods into sacks, and enlisted the help of Glicerio Buensalida and Absalon Medrano to transport the loot.
- The defendants were eventually apprehended on July 16, 1952, following a warrant issued by the Justice of the Peace Court of Lupi.
- Investigation and Evidence
- Post-apprehension, police investigations were conducted:
- Different investigating officers handled the interrogations of Enguero and Tariman (Capt. Dominador M. Gutierrez) and Narvarte and Bueno (First Lieut. Jaope Nobleza).
- The defendants made confessions in written form (Exhibits S, T, U, and V), wherein they admitted to their respective roles in the three robberies.
- Evidence also included the recovery of various items from each accused:
- From Enguero: a gray skin suit, a bottle of Siu Tung wine, a pair of tennis shoes, a raincoat, a balisong, a flashlight, and a pistol.
- From Narvarte: a towel, a skin pant, shoes, and a hammer.
- From Bueno: a birthstone ring, a blue pant, a jacket, and from Tariman: a pair of leather shoes.
- An inventory of the recovered items (Exhibit J with its subdivisions J-1, J-2, J-3, and J-4) was duly signed by the accused, confirming the recovery and detailing the items associated with each perpetrator.
- Legal Proceedings and Appeal
- The defense contended, relying on People vs. de Leon, that the appellants were guilty of one continuous crime instead of three separate crimes.
- However, the evidence demonstrated that after committing the first robbery, the group proceeded to commit subsequent robberies at different locations.
- Jose Tariman subsequently withdrew his appeal.
- As no factual disputes were raised, the sole error assigned was the conviction for three robberies rather than a single offense.
- The Court of Appeals certified the appeal to the Supreme Court for resolution.
Issues:
- Whether the trial court erred by convicting the accused of three separate robberies in band rather than a single continuous offense.
- The defense argued that, similar to the People vs. de Leon precedent, the series of robberies should be treated as one crime due to their connected nature.
- Whether the separate acts, occurring in distinct locations and involving distinct rounds of robbery, legally justify multiple convictions under the applicable statutes.
- The proper application of the rule regarding robbery in band under Article 294, Paragraph 5 of the Revised Penal Code, as amended by Republic Acts No. 18 and 373, and how the indeterminate sentence law interacts with these provisions.
- Determining if the penalties imposed (ranging from prision correctional to prision mayor) conform with the requirements set forth in the Revised Penal Code and its subsequent amendments.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)