Title
People vs Lazaro
Case
G.R. No. 11562
Decision Date
Aug 31, 1916
Three defendants are convicted of robbery in band with serious physical injuries, leading to a modified sentence by the Supreme Court.
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Case Digest (G.R. No. 11562)

Facts:

  • Defendants: Simon Lazaro, Juan Lazaro, and Francisco Manzano.
  • Convicted of robbery in band with serious physical injuries against Catalina Madrazo on August 20, 1916, in Mabini, Urdaneta, Pangasinan.
  • An armed group of at least seventeen men surrounded Madrazo's house around 10:00 PM.
  • Two assailants, armed with bolos, entered the house and demanded money from Catalina and her granddaughter, Maura Lomboy.
  • The assailants struck both women with the flat sides of their bolos, causing injuries.
  • Catalina initially handed over P 40 and P 150; under threat, Maura retrieved an additional P 2,020 from a hidden stash.
  • Jorge Galang attempted to help but retreated due to the number of bandits; he later returned with Inocencio Alberto, who was severely injured by the robbers.
  • The robbers fled after the commotion.
  • Catalina did not recognize the robbers, while Maura identified Simon and Juan Lazaro but initially hesitated due to fear.
  • Other witnesses corroborated the presence of the Lazaro brothers.
  • The trial court sentenced the defendants to nineteen years, one month, and eleven days of cadena temporal, along with accessory penalties and indemnification to the victim.

Issue:

  • (Unlock)

Ruling:

  • The trial court's finding of guilt was upheld.
  • The qualification of the crime as robbery in band was affirmed.
  • The injuries were deemed serious and fell under the relevant provisions of the Penal Code.
  • The aggravating circumstance of nocturnity was properly considered....(Unlock)

Ratio:

  • The Supreme Court affirmed the trial court's findings, emphasizing the credibility of witnesses, particularly Maura Lomboy, who had a clear opportunity to recognize the robbers due to a lighted lamp.
  • The initial hesitance of witnesses to identify the robbers was understandable given the fear and confusion during the incident.
  • The injuries inflicted on Inocencio Alberto were serious, resulti...continue reading

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