Case Digest (G.R. No. 1332)
Facts:
- Geronimo Luzon was charged with illegal detention.
- The incident occurred on November 22 or 23, 1900, in Marilao, Bulacan.
- Luzon, along with seven others (six armed), forcibly entered Celedonia Santos's home.
- They unlawfully detained Celedonia Santos, her husband Gregorio Mistica, and Felipe Santos, transporting them to Tagalog.
- The group also committed robbery at the Santos residence.
- Celedonia was held captive for nine days; Gregorio's fate was uncertain, with unproven allegations of his assassination.
- Felipe Santos escaped on the night of the abduction.
- Luzon claimed an alibi, stating he was ill elsewhere during the incident.
- The Court of First Instance of Bulacan found him guilty and sentenced him to 17 years, 4 months, and 1 day of cadena temporal.
- Luzon's request for amnesty under a presidential proclamation was denied.
- A motion for a new trial was also rejected due to lack of sufficient grounds.
Issue:
- (Unlock)
Ruling:
- The court denied the motion for a new trial due to failure to meet necessary conditions.
- The court affirmed the sentence of 17 years, 4 months, and 1 day of cadena...(Unlock)
Ratio:
- The denial of the new trial motion was based on the absence of newly discovered evidence that could materially impact the case outcome.
- The defendant's motion lacked specificity regarding the new evidence and its potential effect on the trial result.
- For a new trial, evidence must be discovered post-trial, be material, and not merely cumulative or impeaching.
- The court noted that the defendant's silence about Gregorio M...continue reading
Case Digest (G.R. No. 1332)
Facts:
In the case of The United States vs. Geronimo Luzon, the defendant, Geronimo Luzon, was charged with the crime of illegal detention. The events transpired on or about November 22 or 23, 1900, in Marilao, Bulacan, when Luzon, accompanied by seven other individuals—six of whom were armed—forcefully entered the residence of Celedonia Santos. During this incident, they unlawfully took possession of Celedonia Santos, her husband Gregorio Mistica, and another individual named Felipe Santos, subsequently transporting them to the sitio of Tagalog. The group also robbed the Santos household. Celedonia Santos was held captive for nine days, while Gregorio Mistica's fate remained unknown throughout the trial, with allegations of his assassination by the accused and his companions unproven. Felipe Santos managed to escape on the same night of the abduction. The defendant attempted to establish an alibi, claiming he was sick at a different location during the incident. The Court of First Instance of Bulacan found Luzon guilty and sentenced him to seventeen years, four months, and one day of cadena temporal, along with the costs of the trial, under paragraph 2 of Article 483 of the Penal Code. Following this, Luzon's attorney filed a motion for inclusi...