Title
People vs. Logario
Case
G.R. No. 1714
Decision Date
Apr 14, 1905
Defendants convicted of bandolerismo for forming an armed robbery band; Supreme Court reduced death penalty to 25 years, citing lack of leadership evidence and proportionality.
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Case Digest (G.R. No. 1714)

Facts:

    Background of the Case

    • The defendants were charged with the crime of bandolerismo, which involved allegations of forming a band of robbers.
    • The charge specified that from on or about December 12, 1902, until April 1903, the defendants conspired with other individuals to commit robbery by stealing carabaos and other personal property using force and violence.
    • The complaint alleged that the defendants were equipped with guns, revolvers, and other deadly weapons and that they roamed the highways and countryside to carry out their criminal acts.

    Arrest, Jurisdiction, and Trial

    • It was contended that the defendants operated within the police jurisdiction of Manila during much of the period in question, and were eventually captured within the city.
    • The case was initially tried before the Court of First Instance of Manila, where the evidence led the judge to convict each defendant on the charges.
    • The original sentence imposed by the lower court was the penalty of death for each of the accused.

    Consolidation with a Related Cause

    • The case was later tried en consulta alongside the case of United States vs. Calixto Aquino et al.
    • The prosecuting attorney and the attorneys for the defendants agreed that the same body of evidence should be applied to both causes, linking the judicial proceedings of these cases.

    Evidence and Findings at Trial

    • The evidence presented during trial established beyond reasonable doubt that the defendants were guilty of the crime charged in the complaint.
    • However, the evidence failed to show that the defendants had organized the alleged band of robbers, or that they held positions as chiefs or leaders within such an organization.
    • The involvement of the defendants was determined to be similar to that of other accused individuals (specifically, Potenciano Comia and Urbano Villanueva) who received a lesser penalty.

Issue:

    Determination of Criminal Liability

    • Whether the evidence conclusively established that the defendants had formed or led a band of robbers, as charged in the complaint.
    • Whether the extent of the defendants’ participation warranted the imposition of the death penalty.

    Comparative Assessment of Punishment

    • The issue of reconciling the degree of involvement of the defendants with that of other accused persons who received a lighter sentence (imprisonment for twenty-five years).
    • Whether the penalty should be adjusted in light of the evidence that the defendants did not assume a leadership role in the alleged criminal enterprise.

    Applicability of Conjoined Evidence

    • The legal question as to whether the shared evidence between this case and the United States vs. Calixto Aquino et al. case could justly support different penalties for individuals with varying levels of involvement.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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