Title
People vs. Magramo y Manlolo
Case
G.R. No. 43754
Decision Date
Oct 15, 1935
Defendants convicted of robbery with slight physical injuries, but dissent argues evidence supports only a conviction for physical injuries.
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Case Digest (G.R. No. 43754)

Facts:

  • Defendants: Cirilo Magramo y Manlolo and Teofilo Gutierrez y Matuman.
  • Charged with robbery with slight physical injuries in the Court of First Instance of Manila.
  • Incident date: March 21, 1935, in Manila.
  • Complainant: Ty Liang Seng, who was assaulted by the defendants.
  • Defendants conspired to attack Ty Liang Seng, inflicting injuries requiring medical attention for more than one but less than ten days.
  • Amount taken: P9.93, consisting of various bills and coins.
  • Magramo was identified as a habitual delinquent with prior theft convictions; Gutierrez was a recidivist with previous slight physical injury convictions.
  • Prosecution evidence included:
    • Testimony of Ty Liang Seng, who was assaulted after purchasing milk.
    • Witness Uy Gao corroborated the assault and theft.
    • Detective Pedro Galvez testified about the injuries and investigation.
  • Trial court verdict: Both defendants found guilty.
  • Sentences: Gutierrez received six months and one day to ten years; Magramo received three years, eight months, and one day, with an additional penalty for habitual delinquency.
  • Defendants appealed, claiming evidence was inconsistent and insufficient.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the evidence was sufficient to establish the defendants' guilt for robbery with slight physical injuries beyond a reasonable doubt.
  • The Court affirmed the trial court's ...(Unlock)

Ratio:

  • The Supreme Court found the testimonies of Ty Liang Seng and Uy Gao credible and consistent, providing a clear account of the assault and theft.
  • The defendants' actions indicated intent to rob, as they attacked Ty Liang Seng immediately after he left the store with money.
  • The Court considered the defendants' prior convictions in ...continue reading

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