Case Digest (G.R. No. L-15823-26)
Facts:
The People of the Philippines v. Balbal Sigayan, G.R. Nos. L-18523-26. April 30, 1966, the Supreme Court En Banc, Per Curiam.
The prosecution (plaintiff-appellee) charged Balbal Sigayan (defendant-appellant) jointly with others in four criminal informations arising from incidents on January 8, 1955. The accused originally stood with several co-defendants — notably Makasiro Tamiara, Demasindel Timba (alias Dimasimpon), and Desoma Timba (alias Disomangcop) — in Criminal Cases Nos. 1690 and 1797 (robbery with homicide) and Nos. 1841 and 1843 (murder). Motions by the City Attorney resulted in the dismissal of the complaint against Datu Ibra Tamano in Crim. No. 1690; Demasindel Timba was released from some informations and utilized as a state witness; prosecutions against Desoma Timba were dismissed for insufficiency of evidence.
The trial court found that, on the night of January 8, 1955, a band of armed men led by Makasiro Tamiara entered two neighboring houses in Kalubihon, Dalipuga, Iligan City, riddled the houses with bullets and killed several occupants — Anacleto Madrina and his daughters Juana and Elena in one house, and Leodegario Mendez and Laureano Alongay in the other — and robbed the Madrina household of P2,500 in cash and firearms (total loss P3,050). Eleven members of the band including Makasiro were later killed in an ambush by the City Police; Sigayan was captured carrying part of the loot.
At trial Sigayan testified he had been forcibly taken by the group and coerced at gunpoint to accompany them and carry loot; he claimed he was left under guard and heard the shooting but did not participate. The prosecution relied principally on the testimony of the state witness Demasindel Timba, which the trial court found clear, convincing, and corroborated by other witnesses (including acting P.C. Provincial Commander Major Songcoya) and by a written declaration of Sigayan attested before a municipal judge. The trial court convicted Sigayan of robbery with homicide in Crim. Nos. 1690 and 1797 (imposing the death penalty, aggravated by dwelling, band, evident premeditation and treachery) and of murder in Crim. Nos. 1841 and 1843 (sentenced to reclusion perpetua). Sigayan did not appeal the convictions in Crim. Nos. 1841 and 1843; because death sentences were imposed in Crim. Nos. 1690 and 1797, those convictions were subject to automatic review by this Court under Section 9, Rule 118 of the old Rules of Court (now Sec. 9, Rule 122).
On automatic review the Supreme Court examined credibility disputes (prosecution portraying Sigayan as an active, armed participant; defense asserting coercion), the sufficiency of corroboration, the non-presentation of Desoma Timba as a witness, the claimed mitigating circumstance of voluntary surrender, and the applicability of aggravating circumstances. The Court sustained the trial court’s credibility findings, rejected the contention that the deaths at Mendez’s house were mer...(Subscriber-Only)
Issues:
- Does automatic review by the Supreme Court apply to the death sentences imposed in Criminal Cases Nos. 1690 and 1797?
- Was the conviction of Balbal Sigayan for robbery with homicide and murder sustainable given his claim that he was forcibly taken and merely coerced to accompany the band?
- Were the killings at Leodegario Mendez’s house accidental (not intended), so as to negate separate convictions for murder?
- Did the prosecution’s non-presentation of Desoma Timba as a witness amount to suppression of evidence requiring reversal?
- Was Sigayan’s alleged surrender a voluntary mitigating circumstance, and did the aggr...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)