Case Digest (G.R. No. 10174)
Case Digest (G.R. No. 10174)
Facts:
The United States v. Severino Perez, Abdon de Leon, Faustino Manago, and Lorenzo Reyes, G.R. No. 10174. November 06, 1915, the Supreme Court, Araullo, J., writing for the Court.The criminal complaint, filed June 6, 1914 by the fiscal of Pampanga, charged Severino Perez, Abdon de Leon, Faustino Manago and Lorenzo Reyes with robbery with murder committed about July 4, 1912 at the fishery house of Damaso Valencia in barrio Lawa, Lubao, Pampanga. The complaint alleged that the accused, with Julio Santos (since deceased), approached the house under the pretense of buying fish, then attacked and killed Valencia (38 wounds, one by bullet), bound his wife Miguela Sibug, and stole money and jewelry from a trunk.
The four accused were arraigned and pleaded not guilty. During trial the fiscal moved to exclude Lorenzo Reyes from the complaint so he could be used as a prosecution witness; the trial court granted the motion. On July 31, 1914 the Court of First Instance of Pampanga found Severino Perez, Abdon de Leon and Faustino Manago guilty and sentenced them to death, ordered indemnity of P1,000 to the heirs and assessed costs. Lorenzo Reyes had been treated as a witness for the prosecution; Julio de los Santos was already dead.
On review before this Court, counsel for the defendants attacked (1) sufficiency of proof beyond reasonable doubt and (2) the characterization of the offense (that they were sentenced for "robbery with murder" rather than for robbery separate from homicide). The trial record showed testimony by Miguela Sibug identifying the intruders and describing the tying and robbery; testimony by Lorenzo Reyes (excluded from indictment) who observed the assault from the embankment and received P23 from the group after the incident; discovery and arrests of the men months later; and extra‑judicial inculpatory statements by Faustino Manago while detained (to a Constabulary lieutenant, the municipal president and a municipal policeman) naming his companions in the assault. The defense offered denials and alibi witnesses for De Leon and Manago, which the trial court found unconvincing.
This Court reviewed the evidence, assessed witness credibility (including accomplice testimony and Manago’s extra‑judicial statements), and considered whether the statutory offense was robbery with murder or the separate statutory offense of robbery with homicide under the Penal Code. The matter came to this Court as a review of the trial court’s judgment (appeal for review of sentence and conviction).
Issues:
- Was the guilt of Severino Perez, Abdon de Leon and Faustino Manago proven beyond reasonable doubt?
- Was the proper legal characterization and penalty "robbery with murder" as the trial court held, or should the conviction be for the (distinct) crime of robbery with homicide under the Penal Code?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)