Facts:

The case involves the defendants Simon Lazaro, Juan Lazaro, and Francisco Manzano, who were convicted of robbery in band with serious physical injuries against Catalina Madrazo on August 20, 1916, in the barrio of Mabini, Urdaneta, Pangasinan. At approximately 10:00 PM, an armed group of at least seventeen men surrounded Madrazo's house. Two members of the group, armed with bolos, entered the house, where they demanded money from the 60-year-old Catalina and her granddaughter, Maura Lomboy. During the robbery, the assailants struck both women with the flat sides of their bolos, causing injuries. Catalina initially handed over P 40 and P 150, but when threatened with death, Maura retrieved an additional P 2,020 from a hidden stash.

Jorge Galang, responding to the women's cries for help, attempted to enter the house but retreated upon seeing the large number of bandits. He later returned with Inocencio Alberto, who was attacked and severely injured by the bandits. Th...

Facts:

1. Incident Overview:

   • On August 20, 1916, around 10 PM, an armed band of at least 17 men surrounded the house of Catalina Madrazo in the barrio of Mabini, Urdaneta, Pangasinan.
   • Two armed men entered the house, demanded money, and struck Catalina and her granddaughter, Maura Lomboy, with the flat sides of their bolos.
   • Catalina handed over P40 and P150, while Maura, fearing for her grandmother’s life, retrieved P2,020 from a hiding place and gave it to the robbers.

2. Injuries and Resistance:

   • Jorge Galang and Inocencio Alberto attempted to help but were attacked by the bandits below. Alberto suffered a severe bolo wound to his arm, rendering it permanently useless.

3. Witness Testimonies:

   • Catalina Madrazo: Did not recognize the robbers due to fear and physical trauma.
   • Maura Lomboy: Initially claimed she did not recognize the robbers but later identified Simon Lazaro and Juan Lazaro as the men who entered the house.
   • Jorge Galang: Initially denied recognizing the robbers but later identified Simon and Juan Lazaro when they were arrested.
   • Telesforo Baltazar: Testified that he was forced to accompany the band and identified several members, including Francisco Manzano.
   • Rufino Galina: Testified that Francisco Manzano invited him to join the robbery and later confirmed the robbery’s success.

4. Defense Arguments:

   • The defendants (Simon Lazaro, Juan Lazaro, and Francisco Manzano) denied involvement, claiming they were falsely accused due to personal enmity.

5. Trial Court Findings:

   • The trial court convicted the defendants of robbery in band with serious physical injuries, imposing a penalty of 19 years, 1 month, and 11 days of cadena temporal.

Issue:

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Ruling:

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Ratio:

1. Identification of Defendants:

   • The testimonies of Maura Lomboy and Jorge Galang, corroborated by other witnesses, sufficiently established the identity of Simon Lazaro and Juan Lazaro as the robbers who entered the house.
   • The initial reluctance of witnesses to identify the robbers was due to fear, which was understandable given the violent nature of the crime.

2. Qualification of the Crime:

   • The crime was properly classified as robbery in band under Article 503, paragraph 4, as the robbery involved a group of armed men and resulted in serious physical injuries.
   • The trial court erred in applying paragraph 3 of Article 503, as the complaint did not allege the loss of a principal member, only the loss of use of the arm.

3. Aggravating Circumstances:

   • Nocturnity was correctly applied as the crime was committed at night to facilitate the robbery and ensure impunity.

4. Penalty Adjustment:

   • The penalty was reduced to 14 years and 8 months of cadena temporal, as the trial court incorrectly applied the maximum penalty under paragraph 3 of Article 503.