Case Summary (G.R. No. L-54901)
Factual Background
On the night of November 1, 1973, in Rosario, Cavite, taking advantage of the All Saints' Day festivities, Ricardo Abueg and Deogracias San Pedro entered the home of Diosdado Maraya, seeking to partake in food offerings. Initially welcomed, the atmosphere turned violent when Abueg attacked Norberto Alcaraz with a "chaco," leading to further chaos inside the house. Marciana Maraya, the mother of Diosdado, was later struck in the chest when Abueg forcibly entered the residence, causing her subsequent death from the injuries inflicted. The accused then proceeded to vandalize property and steal clothing.
Procedural History
The trial court rendered a judgment on March 23, 1976, convicting both defendants of robbery with homicide. Given their age (19 years old) at the time, the execution of the death penalty was suspended in accordance with Philippine law, directing their confinement instead to a youth rehabilitation facility.
Nature of the Charges
Abueg and San Pedro faced charges of robbery with homicide. Although they pleaded not guilty, trial evidence presented compelling accounts of their violent actions against the Maraya household, including the fatal attack on Marciana Maraya and the theft of personal belongings valued at P393.00.
Appellant's Claims on Appeal
In his appeal, Abueg asserted several arguments, including the lack of proven conspiracy between him and San Pedro, which he claimed should reduce his culpability to homicide solely. He contested the trial court's findings that he was guilty of robbery with homicide, positing that the crime did not stem from a prior agreement to commit robbery and that his actions were more reactionary and not premeditated. Moreover, he raised a defense of mental incapacity, based on a psychological evaluation.
Court's Findings on Conspiracy and Intent
The court found no merit in Abueg's defense regarding conspiracy, noting that cooperation and shared intent to commit robbery were evident from their simultaneous actions during the incident. The forceful ramming of the door and subsequent destruction of property were indicative of a criminal design that fulfilled the elements of robbery. Moreover, while initial ventures to exact personal vengeance were acknowledged, the escalation of actions leading to robbery and homicide was decisive in affirming the charge.
Mitigating Circumstances
Abueg's argument concerning a lack of intent to do grievous harm was partially considered. The court recognized that the trajectory of events indicated racing passions rather than a pre
...continue readingCase Syllabus (G.R. No. L-54901)
Case Background
- This case involves the criminal prosecution of Ricardo Abueg and Deogracias San Pedro for the crime of robbery with homicide.
- The incident occurred on November 1, 1973, in Rosario, Cavite, where the accused allegedly conspired and committed acts of violence against Marciana Maraya and her family.
- The prosecution contended that the accused entered the Maraya residence, inflicted harm leading to Marciana's death, and stole items of value.
Incident Description
- On the evening of the crime, the Maraya family was at home celebrating All Saints' Day.
- Ricardo Abueg and Deogracias San Pedro entered the house uninvited, initially asking to partake in food.
- Following a brief interaction, Abueg attacked Norberto Alcaraz, a family member, with a "chaco," leading to a violent confrontation.
- After retreating, the two accused returned, forcibly opened the door, and Abueg struck Marciana Maraya, resulting in her death.
- The accused proceeded to destroy property and steal clothing valued at P393.00.
Medical Examination and Police Investigation
- Marciana Maraya was pronounced dead upon arrival at Maternity Hospital, with medical findings indicating death was due to traumatic shock from injuries sustained.
- Investigating officers collected evidence, including weapons used in the assault and statements from witnesses corroborating the events.
- The poli