G.R. No. 11042 - People vs Bagsic

The case began in the Court of First Instance of Nueva Ecija through a complaint filed by the provincial fiscal.
The complaint charged Teofilo Lagman, Felicisimo Bagsic, Juan de Guzman, and Doroteo Mendiola with the crime of robbery, committed on or about January 15, 1915, in the municipality of Guimba, Nueva Ecija.
It was alleged that the defendants, armed with clubs and acting in conspiracy, assaulted an 80‑year‑old man, Juan de Ocampo, struck him on the head, and robbed him of P150.30.

On the night in question, Juan de Ocampo left his house to purchase bread at a local bakery, carrying a pocketbook containing P150.30 meant for his nephews’ expenses.
As he returned, near the schoolhouse, he was violently attacked on the right side of the head and right ear by Felicisimo Bagsic who wielded a club.
The blow rendered him unconscious, and upon regaining consciousness, Ocampo discovered the loss of his pocketbook and the sum inside.
His family later found him at a nearby store and offered him aid; the incident was subsequently reported to the municipal president.

The prosecution presented the testimonies of witnesses including Basilio Gamboa, Sixto Gamboa, and Clemente Caballero, who attested to:

The prior knowledge of Ocampo’s possession of money by virtue of their association with the local parish.
A meeting held in a market stall where, under the direction of defendant Doroteo Mendiola, plans were made to intercept Ocampo.

Felicisimo Bagsic, carrying a club, struck Ocampo.
Juan de Guzman and Doroteo Mendiola then seized Ocampo’s pocketbook.
Shortly after the crime, a part of the stolen amount was offered by Teofilo Lagman to one of the witnesses, Sixto Gamboa.

The testimony of the accomplices, though uncorroborated by independent evidence, was deemed competent based on historical precedents.

Doroteo Mendiola was in the barrio of Pucac, well away from the scene.
Felicisimo Bagsic, Juan de Guzman, and Teofilo Lagman were at a social gathering in Julio Bagsic’s house during a festival.

Several defense witnesses (Julio Bagsic, Teofilo Ramos, and Ponciano Malonat) testified to an alibi suggesting the defendants remained indoors until after the crime was committed.
Contradictions arose:

Timeline discrepancies in the testimony regarding when guests entered or left the house.
Testimonies placing some defendants near the crime scene despite claims of being at the social gathering.
Conflicting accounts about the whereabouts of key figures such as Sixto Gamboa, with defense witnesses unable to conclusively disassociate him from the crime scene.

The distance between Pucac and San Juan de Guimba could be traversed within a short time, undermining the claimed alibi.
The collective evidence from prosecution witnesses placed the defendants in or near the scene of the crime.

The testimony of the accomplices, although not corroborated by other evidence, was accepted based on longstanding principles and judicial discretion regarding witness credibility.
Ultimately, the comprehensive factual record established the direct participation of each defendant in the commission of the crime.

Whether the trial court erred in overruling the defendants’ motion for dismissal predicated on the alleged insufficiency of the prosecution’s evidence.

Whether the uncorroborated testimony of accomplices could, if believed, sustain a verdict of guilt beyond reasonable doubt.
The weight to be given by the court to these testimonies in light of conflicting defense claims.

Whether the alibi provided by the defendants and supported by defense witnesses was sufficient to negate the prosecution’s evidence.
The impact of contradictory and imprecise timeline accounts on the credibility of the defense’s assertions.

Whether the trial court’s decision to classify the offense as robbery with violence (as defined in Article 502 and punished in paragraph 5 of Article 503 of the Penal Code) was correct.
Consideration of whether the slight disfigurement (injury to the ear) should result in a different classification or penalty.