Case Digest (G.R. No. L-4158)
Facts:
United States v. Mateo Carino et al., G.R. No. 4158, March 20, 1908, the Supreme Court, Carson, J., writing for the Court. The plaintiff was the United States; the defendants were Mateo Carino, Gabriel Valenzuela, Daniel de Guzman, Jose Valenzuela, Isidro Valenzuela, and Narciso Centeno.About midnight on April 24, 1907, the six named defendants, armed with bolos, forced their way into the house of Francisco Darapisa in barrio Manaoag, Pangasinan, accompanied by several others who did not enter. The intruders ordered Darapisa to lie face down; he refused, wounded one assailant with his bolo, and fled through a window while pursued. Mrs. Darapisa escaped temporarily to a neighbor’s house and, upon returning after the assailants left, found her trunk rifled and P7 taken; the neighbors found her husband’s body some 30 yards away with fourteen wounds, many fatal.
The defendants were charged with robo con homicidio (robbery with homicide) with aggravating circumstances of having been committed by an "armed band," at night, and in the dwelling. The trial court convicted the accused and imposed the death sentence on the perpetrators, except that Narciso Centeno received cadena perpetua and did not appeal. The convictions and sentences of the other accused were brought before the Supreme Court en consulta.
At trial the widow identified each defendant as a member of the band; the defense tested her identification by, with court permission and without her knowledge, withdrawing a defendant and substituting another prisoner similarly attired, whom the widow immediately identified. Centeno had confessed and named co-defendants, but the trial court refused to consider his confession except against Centeno himself. Other witnesses saw some accused carrying a hammock at daybreak; Mateo Carino was later found with a fresh breast wound at Gabriel Valenzuela’s house and attempted to conceal it. Blood-smeared bolos and a spear were found hidden at Vale...(Pro-only)
Issues:
- Was the identity of the defendants and their guilt proved beyond a reasonable doubt?
- Could Narciso Centeno’s confession implicating others be considered against the co-defendants?
- Was the imposition of the death sentence proper under the circumstances (robbery with homicide with alleged aggr...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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