Case Digest (G.R. No. L-37937)
Facts:
The case involved the People of the Philippines as the plaintiff-appellee and Mauro Vallente y Javier as the accused-appellant, under G.R. No. L-37937, decided on September 30, 1986. The initial charge against Vallente and several co-accused was robbery with homicide, as outlined in an Information filed on April 11, 1973, in the Circuit Criminal Court of Manila. This case stemmed from events that transpired on April 7, 1973, when the accused conspired to rob a passenger jeepney. The incident began when the complainant, Natividad Pacheco, who was carrying PHP 830.00 in cash from her business, boarded a jeepney alongside her driver, Vito Robles. Unknown to them, three of the accused, including Vallente, were already inside the vehicle. During the robbery, as Balinas announced that it was a holdup, Vallente attempted to grab the bag containing the money while Robles tried to defend Pacheco. A struggle ensued, which led to Vallente and his co-accused violently attacking Robles, res
Case Digest (G.R. No. L-37937)
Facts:
- Background of the Case
- The case involves multiple accused charged with the crime of robbery with homicide pursuant to an Information dated April 11, 1973, filed with the Circuit Criminal Court of Manila.
- The accused include Carlos Medina, Reynaldo Dantes, Alberto Gucvarra, Leonardo Concepcion, Conrado Bucno, Honorio Lirio, Mauro Vallente, and Rodolfo Balinas.
- The incident took place on or about April 7, 1973, in a passenger jeepney, wherein it is alleged that the accused, armed with guns and a knife, executed a planned holdup.
- Sequence of Criminal Acts
- The Information alleges that during the robbery the accused forcibly seized a paper bag containing P830.00 from Natividad Pacheco, the owner of the money.
- In furtherance of their plan and to overcome resistance, they attacked Vito Robles—companion of the complainant—striking him with a gun and subsequently shooting him, which resulted in his death.
- The act of taking (even if the money was later dropped or disposed of) constitutes the consummation of the crime, as possession was attained by force and intimidation.
- Trial Court Proceedings and Initial Judgment
- On August 23, 1973, the trial court delivered its decision:
- Accused Reynaldo Dantes, Mauro Vallente, and Rodolfo Balinas were found guilty as principals, with death sentences imposed upon them based on aggravating circumstances such as craft and abuse of superior strength.
- Accused Carlos Medina was sentenced to life imprisonment due to the absence of any mitigating circumstance.
- Other accused, namely Leonardo Concepcion, Alberto Gucvarra, Conrado Bucno, and Honorio Lirio, were acquitted due to failure of the prosecution to prove their guilt beyond reasonable doubt, and were ordered released.
- The judgment also ordered joint and several indemnification to the heirs of the deceased and to the complainant.
- Evidentiary Record and Factual Developments
- The case is further complicated by subsequent developments:
- Some of the convicted co-accused (Reynaldo Dantes and Rodolfo Balinas) died while in police custody as noted in later communications by prison officials.
- Mauro Vallente, the appellant, escaped from the New Bilibid Prison on June 16, 1974, making his case subject to an automatic review despite his being at large.
- The events leading up to and during the commission of the crime were recounted in detail in the Appellee’s Brief:
- A meeting on April 6, 1973, at Carlos Medina’s residence in Tondo, Manila, where the plan was hatched to rob a Caltex gasoline station.
- On the evening of April 7, 1973, the robbery was executed inside a jeepney when Natividad Pacheco, accompanied by Vito Robles, boarded the vehicle.
- The hold-up was initiated when the accused, after boarding the jeepney, signaled and announced the robbery, leading to a physical confrontation inside and outside the vehicle which resulted in Robles being shot.
- Testimonies and Evidence
- Complainant Natividad Pacheco’s testimony was pivotal in establishing the taking of money by force:
- She described the sequence of events with emphasis on the drawing of guns, the declaration of “this is a hold-up,” and the subsequent forcible snatching of the bag from her lap.
- Despite some admitted lapse in specifics—likely due to shock and the traumatic nature of the event—her core testimony affirmed the consummation of the robbery.
- Additional evidence, particularly the written statement of Reynaldo Dantes, confirmed:
- The participation of Mauro Vallente in grappling with Vito Robles to secure possession of the money.
- The collective conduct of the accused which demonstrated a common design to effectuate the robbery despite ensuing complications.
- Appellant’s Alleged Errors and Subsequent Arguments
- Mauro Vallente contended that:
- The case should be considered as attempted robbery with homicide rather than a consummated crime.
- He did not directly participate in the killing of Vito Robles, claiming that the fatal shooting was the “instant personal decision” of another co-accused.
- The aggravating circumstances, particularly the use of craft and abuse of superior strength, were either inapplicable or misapplied in his case.
- The disparate sentencing—death for him while others received life imprisonment or were acquitted—was unfair and legally unsound.
- The factual record and testimonies did not support the appellant’s contentions, as the evidence clearly placed him in active participation in the robbery with homicide.
- Final Judicial Resolution
- The reviewing court affirmed the trial court’s decision in essence for all accused.
- However, due to a lack of necessary votes, the imposition of the death penalty on Mauro Vallente was reduced to reclusion perpetua.
- Additionally, the order for indemnification was modified, increasing the amount payable to the heirs of Vito Robles from P12,000.00 to P30,000.00.
- The judgment was affirmed on the basis that the evidence presented incontrovertibly demonstrated the consummation of the crime and the active participation of each of the accused, including Mauro Vallente.
Issues:
- Classification of the Crime
- Whether the offense committed by the accused, particularly Mauro Vallente, should be considered a consummated robbery with homicide or merely an attempted robbery with homicide.
- Participation and Liability
- Whether appellant Mauro Vallente can be held liable as a principal in the crime given the contention that he did not exercise independent decision-making regarding the killing.
- Whether his alleged mere association with the crime suffices to establish his active participation in the overall criminal design.
- Applicability of Aggravating Circumstances
- Whether the trial court was correct in finding that aggravating circumstances—specifically, the use of craft and the exploitation of superior strength—applied to Mauro Vallente’s conduct.
- Whether these factors warranted the imposition of the death penalty, especially in contrast with the lighter sentences given to some co-accused.
- Differential Sentencing Among Co-Accused
- The legal basis for imposing the death penalty on certain accused while sentencing others to life imprisonment or even acquitting them.
- Whether the differences in penalties undermine the principle of co-responsibility in a common conspiracy to commit robbery with homicide.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)