G.R. No. 126126 - People vs. Sabadao

On June 23, 1987, a robbery with homicide occurred at the Rizal Commercial Banking Corporation (RCBC) in Batac, Ilocos Norte.
Four armed men—including accused-appellants Sales Sabadao and Vidal Valdez, along with Carlos Mayo and Albert Abangon (the fourth identified as Charlo Morales/Bayed)—entered the bank, using violence and intimidation.
The robbers aimed to seize cash and, in the process, unlawfully appropriated the firearms of the bank’s security guards.

The incident began around 9:55 a.m. when the malefactors, armed with unlicensed firearms, stormed into RCBC.

They subdued Security Guard Romeo Aganon by forcibly taking his shotgun and later fatally shot him.
In the ensuing melee, responding police officers, including Pfc. Arnulfo Valera, were engaged and fatally wounded.
Additionally, one of the conspirators, later identified as Charlo Morales, was killed during the exchange of gunfire.

The robbery involved the forcible opening of the bank vault resulting in the loss of cash amounting to P4,200.00.
Testimonies revealed a premeditated scheme of entry and a concerted plan that evidenced the existence of a conspiracy among the malefactors.

Six officers/employees of RCBC, including the branch manager, security guards, cashiers, and bank personnel, provided detailed accounts.
Two clinicians—the medico-legal officer and the autopsy report by Dr. Artemio Gambalan—established the cause of death for the victims.
Several police officers testified regarding the recovery of weapons and their observations at the scene.

Both accused-appellants, Sales Sabadao and Vidal Valdez, testified in their own defense.
Additional defense witnesses attempted to support alibi claims (e.g., Sabadao claimed he had been visiting relatives in Batac, and Valdez asserted he was at RCBC only for a fundraising solicitation for his group, GUMIL).
Cross-examinations brought into question the reliability of certain defense statements and alibi narratives.

Accused-appellant Vidal Valdez was found in possession of a .22 caliber revolver (Magnum Tell, Serial No. 143852) with live ammunition, allegedly without the necessary license.
Accused-appellant Sales Sabadao was found with a .45 caliber pistol (Ithaca, Serial No. 2099911) which was connected to the fatal shootings.
Separate criminal complaints were filed for illegal possession of firearms under Presidential Decree No. 1866; however, these charges were later set aside in view of subsequent legal interpretations.

The accused-appellants pleaded not guilty to all charges at arraignment.
During the trial, their petition for bail was granted on December 14, 1988, after extensive presentation of evidence by both the prosecution and defense.
Additional evidence regarding expenses incurred by victim’s heirs for burial and funeral costs was presented later in the trial.

On July 21, 1995, the RTC of Batac, Branch 18 rendered a joint Decision finding Sales Sabadao and Vidal Valdez guilty beyond reasonable doubt of robbery with homicide.
The trial court sentenced them to suffer the penalty of reclusion perpetua and imposed civil liabilities for actual, moral, temperate, and exemplary damages payable to the heirs of the deceased victims.
The court also convicted them for illegal possession of firearms; however, this element was later reconsidered by the appellate court.

Whether the trial court erred in admitting the .45 caliber pistol against Sales Sabadao in Criminal Case No. 2549-18.
Whether the trial court erred in admitting the .22 caliber revolver against Vidal Valdez in Criminal Case No. 2548-18.

Whether the conviction for illegal possession of firearm and ammunition (under Presidential Decree No. 1866) should stand when the unlicensed firearm was used in the commission of a robbery with homicide.
Whether the absence of certification from the Firearms and Explosives Unit of the PNP regarding the unlicensed nature of the seized firearms affects the conviction for illegal possession.

Whether the prosecution established the guilt of the accused-appellants beyond reasonable doubt, considering their alleged non-participation in directly causing the deaths during the incident.
Consideration of the elements of robbery with homicide and if the acts committed by the accused, as part of a concerted conspiracy, suffice for a conviction.