Case Digest (G.R. No. L-16)
Facts:
The People of the Philippines v. Vicente Sope and Mario Cruz, G.R. No. L-16, January 31, 1946, Supreme Court First Division, Jaranilla, J., writing for the Court.
The prosecution charged Vicente Sope and Mario Cruz with robbery in Criminal Case No. 7170 of the Court of First Instance of Manila; their companion Tomas Dimalanta was charged separately in Criminal Case No. 7443 of the same court as having conspired with them. On motion of the fiscal and without defense objection, both informations were tried jointly. The trial court found all three guilty of robbery and sentenced each to an indeterminate penalty (from six months arresto mayor to three years, eight months and one day of prison correctional), ordered indemnity of P80 to the complainant and costs. Dimalanta did not appeal; Sope and Cruz appealed to the Supreme Court, assigning two errors that were reduced by the Court to the single contention that the facts did not establish guilt beyond reasonable doubt.
The complainant, Juliana Chan, testified that on April 8, 1945 at about six o’clock in the evening after selling a ring at Bambang market, a calesa stopped in front of her; Sope and Cruz alighted (whom she identified), Sope pointed a revolver at her while Cruz struck or poked her back with a hard object, and Cruz ordered her into the rig. Dimalanta remained in the calesa. Cruz and Dimalanta purported to be peace officers and accused her of unlawfully dealing in U.S. Army goods, pointing to a bag in the rig which they themselves had brought. The calesa stopped at Herbosa Street before the Victory Cafe where Cruz and Dimalanta even invited her to take coffee; throughout they allegedly intimidated and threatened her until she handed over P200. Thereafter she reported the incident; the three were arrested. Counsel for Dimalanta (Attorney Vega) allegedly offered to settle by returning P200 if she would not testify against Dimalanta; she refused, but later Attorney Resurreccion managed to pay her P120, leaving P80 unrecovered.
On appeal the Supreme Court reviewed the testimony, found the complainant credible despite minor inconsistencies, relied on established precedent that a single convincing witness can sustain a conviction, and regarded the offer to settle by Dimalanta’s attorneys as an implied admission supporting guilt. The Court rejected the defense theory that the incident was bribery/cohecho (i.e., the complainant had been surprised with contraband and voluntarily paid to avoid prosecution), holding instead that the facts established robbery by intimidation ...(Subscriber-Only)
Issues:
- Did the evidence presented at trial establish the guilt of the appellants beyond reasonable doubt?
- Did the facts proven constitute the crime of robbery or, instead, the crime of cohecho ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)