Case Summary (G.R. No. 47899)
Facts of the Case
On the night of January 28, 1937, Manahan, armed with a revolver and accompanied by five accomplices, threatened Catalino Padayao, a servant of Meliton Carlos, to steal approximately fifteen sacks of palay through a hole made in the floor of the camarin. The subsequent night, the group returned to the scene and, utilizing the same modus operandi, intimidated both Padayao and Felicidad Cabungcal (another servant of Carlos) to steal an additional six sacks of palay, employing the same entry point.
Judicial Findings
The Court of Appeals found Manahan guilty of robbery under Article 294, No. 5, of the Revised Penal Code, citing the aggravating circumstance of nocturnity, resulting in a sentence of an indeterminate penalty ranging from 6 months and 1 day of prision correccional to 6 years, 10 months and 1 day of prision mayor, along with the accessory penalties stipulated by law. The court indicated that the issue of indemnity was reserved for resolution in a separate civil action, contingent upon the uncertainties regarding the evidence.
Legal Argument by Petitioner
In challenging the ruling, Manahan contended that because the stolen property consisted of cereals, the lighter penalty established in Article 303 of the Revised Penal Code should have applied. Article 303 pertains to robbery involving the use of force against things, which he argued was more applicable than the charge of robbery involving intimidation against persons.
Court's Legal Reasoning
The court distinguished the nature of the robberies, clarifying that while the act of creating a hole in the floor denotes force upon things, the underlying actions were characterized by violence and intimidation against individual persons. Citing precedent (U.S. vs. Baluyot, 40 Phil. 89, 90), the court held that when robbery involves both force against things and intimidation of persons, the latter
...continue readingCase Syllabus (G.R. No. 47899)
Case Background
- The case involves Alfonso Manahan as the petitioner against the People of the Philippines as the respondent.
- It was decided by the Supreme Court of the Philippines on September 30, 1942, and recorded in 73 Phil. 691, under G.R. No. 47899.
- The events in question occurred on the night of January 28, 1937, involving a robbery incident with multiple participants.
Facts of the Case
- On January 28, 1937, Alfonso Manahan, armed with a revolver, along with five companions, committed robbery against Catalino Padayao, a servant of Meliton Carlos.
- They executed the robbery by using threat and intimidation, successfully taking about fifteen sacks of palay from Meliton Carlos's camarin through an opening made in the floor.
- The following night, the same group repeated their actions against Padayao and Felicidad Cabungcal, another servant, taking an additional six sacks of palay through the same method.
- These actions were reported and led to legal proceedings against Manahan.
Judicial Proceedings
- The Court of Appeals found Manahan guilty of robbery under Article 294, No. 5, of the Revised Penal Code.
- The court noted the aggravating circumstance of noctu