Case Summary (G.R. No. 205128)
Charges and Initial Proceedings
On July 27, 1992, Bachungan and his co-accused were charged with simple robbery for allegedly extorting P5,000 from Diosdada Montecillo through threats and intimidation. The charge stemmed from an incident on July 21, 1992, where police officers allegedly forced Diosdada and Mario Montecillo to part with money under the guise of a legal arrest. The Regional Trial Court of Manila, Branch 19, convicted the three policemen of the charges, sentencing each to imprisonment of six years and one day to ten years, alongside restitution and damages.
Trial and Testimonies
The prosecution presented the Montecillos as key witnesses, detailing a harrowing experience with the accused. They described an encounter with a mobile patrol car where the officers intimidatingly suggested that Mario possessed a deadly weapon, leading to threats of arrest and prosecution. Under duress, Diosdada surrendered money and a wristwatch to the officers. Following the incident, they reported it to the relevant authorities, leading to the identification of the accused.
Court of Appeals Decision
The trial court found the accused guilty, leading to their subsequent appeals. The Court of Appeals affirmed the trial court’s decision on March 31, 1997, prompting further motions for reconsideration from Bacungan and Fortuna, all of which were denied.
Legal Arguments Presented
In the petition for review, Bacungan argued that the Court of Appeals erred by affirming his conviction, insisting that no robbery occurred since the interaction was mutual and voluntary, positing it as a case of bribery instead. He claimed that Mario’s detention was lawful given the alleged possession of an illegal weapon. Conversely, the Solicitor General contended that intimidation was clear as the officers' threats compelled the Montecillos to relinquish their belongings.
Assessment of Intimidation and the Court’s Ruling
After reviewing the case, the court found that the evidence substantiated the claim of intimidation. It agreed with prior rulings, asserting that the accused's actions instilled fear enough to obstruct the victims’ free will, thereby qualifying the incident as robbery. The court also pointed out the aggravating circumstance of "abuse of public position," which was significant given that all accused were officers of the law, utilizing their authority criminally.
Modification of Sentence
In light of the aggravating circumstanc
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Case Overview
- This case involves a petition for review on certiorari filed by Ramon Pablo y Bacungan against the People of the Philippines concerning his conviction for simple robbery.
- The case originated from the Regional Trial Court of Manila, Branch 19, which sentenced Bacungan and his co-accused to imprisonment and ordered them to pay damages to the private complainants.
Background of the Case
- The incident occurred on July 21, 1992, in the City of Manila, where Bacungan and his co-accused allegedly conspired to extort money from Diosdada Montecillo y Olidan.
- The complaint was based on the allegation that the accused, acting as police officers, threatened to arrest Diosdada's brother, Mario Montecillo, for possessing a deadly weapon unless they received P5,000.
Trial Court Proceedings
- Upon arraignment, Bacungan and his co-accused pleaded not guilty.
- The prosecution presented witnesses, including Diosdada and Mario Montecillo, detailing their harrowing experience of intimidation and robbery by the accused.
- The trial court found sufficient evidence of robbery, concluding that the accused used threats and intimidation to extort money from the complainants.
Regional Trial Court's Decision
- The RTC convicted Bacungan and his co-accused of simple robbery and sentenced them to six years and one day to ten years of imprisonment.
- The court ordered them to collectively pay damages: P5,000 as actual damages, P20,000 as moral damages, and P15,000 as