G.R. No. L-17436 - People vs. Manzanilla

The People of the Philippine Islands initiated criminal proceedings against seven accused for robbery by a band.
Two of the accused, Escolastico Manalo and Bernabe de Chavez, were excluded from the information and instead used as prosecution witnesses.
The remaining five accused, including Sergio Manzanilla as the leader, were convicted after trial and sentenced accordingly.

The accused, organized as a band with more than three armed individuals, executed a coordinated robbery along a highway in Tayabas.
They ambushed approximately ten travelers, stopping them on the highway.
The victims were forced into a nearby forest, tied to the trunks of trees, and intimidated with their weapons.
Specific acts include Sergio Manzanilla firing four times at Tomas Villaro when the latter attempted to escape, resulting in a light head injury.
The robbery involved the appropriation of money and personal effects as detailed in the information: an amount of one hundred twenty-six pesos (P126) plus additional articles valued at six pesos (P6), along with clothing and effects appraised at five (P5) and eleven pesos (P11) for other specified complainants.

Of the five convicted accused, four withdrew their appeal, leaving Sergio Manzanilla as the sole appellant contesting the judgment.
Manzanilla filed a motion seeking a new trial based on several claims:

That he was not called to testify.
That the proceeding violated due process.
That some coaccused were improperly used as witnesses for the prosecution.
Allegations that his attorney was bribed by coaccused used as witnesses.
That the trial court rendered its decision without the defense being allowed to present evidence.

The motion was not substantiated by sworn evidence, and discrepancies in the authenticity of the signature cast doubt on its legitimacy.
No specific evidence was presented as to what would have changed the outcome if defense evidence had been introduced.

The exclusion of the two accused as witnesses was deemed in accordance with the law.
The charge alleging bribery of the attorney, Mr. Felix Imperial, lacked even prima facie evidence.
The attorney’s failure to introduce evidence or call the accused to testify was found to be within his lawful discretion, exercised under the belief that it better protected the accused’s rights.

The prosecution established that the crime committed fell under robbery by a band with the element of illegal detention.
Although the specific crime of robbery with physical injuries was noted with respect to the appellant, the information did not expressly allege that point.
Evaluating the facts revealed no attenuating or aggravating circumstances, such as the crime being committed in an uninhabited place.
Based on the evidence, the offense was categorized under Article 503, No. 4 of the Penal Code, with the conduct meriting a penalty higher than that normally imposed for a simple robbery.

Whether the motion for a new trial was meritorious based on the allegations of being denied the opportunity to testify and presenting additional evidence.
Whether the exclusion of two accused from the information (used as witnesses for the prosecution) deprived the appellant of a fair trial.

Whether the alleged bribery of counsel or his failure to present evidence or summon additional witnesses constituted a violation of the accused’s right to due process.
Whether the attorney’s discretionary actions in handling the presentation of evidence were sufficient to warrant a new trial.

Whether the facts demonstrated that the crime committed amounted to robbery by a band with illegal detention.
Whether the penalty imposed (modified upon review) appropriately reflected the crime, particularly considering the appellant’s role as the leader of the band and the accompanying use of unlawful violence and intimidation.