G.R. No. 10174 - People vs Perez

The case arose from a complaint filed on June 6, 1914, by the fiscal of Pampanga charging four men with robbery with murder.
The complaint alleged that on or about July 4, 1912, in the barrio of Lawa, municipality of Lubao, Pampanga, the accused, along with an accomplice (Julio de los Santos, now deceased), employed a ruse by claiming they wished to buy fish, thereby gaining entrance to the house of Damaso Valencia Enriquez.
Upon entry, while Valencia was distracted—reportedly turning his back or engaged in an act of urination—the accused attacked him, inflicting multiple wounds and ultimately causing his death.

The accused, identified as Severino Perez, Abdon de Leon, Faustino Manago, and indirectly Lorenzo Reyes (used as a witness by the prosecution), approached the victim under the pretext of purchasing fish.
Evidence showed that three of the accused were armed with bolos, with one, Severino Perez, additionally carrying a revolver.
The attack was characterized by treachery, as the assailants exploited the late-night hour and the victim’s vulnerability, leading to a fatal assault involving 38 wounds—37 inflicted by pointed cutting instruments and one by a firearm.

Following the murder of Damaso Valencia, the accused proceeded to commit a robbery.
With violence and intimidation, they bound Miguela Sibug, the wife of the deceased, and forcibly seized money (specifically sums in paper and silver coin) and jewelry stored in a trunk inside the domicile.
The robbery and the murder were shown to be part of one continuous and interrelated chain of criminal acts, designed to secure the victim’s property with minimal risk of resistance.

Miguela Sibug, the victim's widow, provided detailed testimony recounting the events inside and immediately outside the house, including identifying the attackers and the sequence of events that led to her husband’s death and the subsequent robbery.
Lorenzo Reyes, although originally an accused and later excluded from the complaint for prosecution purposes, testified regarding the defendants’ movements, their preparations, and corroborated details of the assault and robbery.
Additional witnesses, including members of the Constabulary and local police, testified about post-crime events, such as the attempted arrest in a later encounter in mangrove swamps and subsequent confessions by Faustino Manago, which further established the participation of the accused.
Defense witnesses attempted to establish alibis by placing Abdon de Leon and Faustino Manago in Hagonoy on the date in question; however, the evidence showed that the defendants could have left Hagonoy late on the prior day, committed the crime, and returned unnoticed in the early hours of July 4, 1912.

All evidence pointed to a direct and positive participation of Severino Perez, Abdon de Leon, and Faustino Manago in both the homicide and the robbery.
The acts were executed in concert, evidencing a single complex crime rather than two discrete offenses.
The use of treachery by creating a false impression (the intent to purchase fish) ensured that the victim was unsuspecting and defenseless, facilitating both the murder and the robbery.

Whether the evidence proved beyond all reasonable doubt the direct participation of the accused in the murder and subsequent robbery of Damaso Valencia.
Whether the crime committed should be classified as separate offenses (robbery and murder/homicide) or as a single, unified crime of robbery with homicide.
Whether the exclusion of one of the accused, Lorenzo Reyes, from the complaint (in order to use him as a prosecution witness) impacted the overall evidentiary foundation and the determination of guilt.
Whether the sentence imposed, integrating both the death penalty for the principal crime and accessory penalties including indemnity and disqualification, was appropriate under the law and consistent with the established evidence.