Case Summary (G.R. No. L-2390)
Incident Overview
On the morning of December 23, 1947, a Casa Manila bus was hijacked by five or six armed men while traveling from Batangas to Manila. Pedro Baldera, identified as a participant, fired a weapon during the hold-up, resulting in multiple injuries to passengers. Jose Cabrera succumbed to his injuries the following day. Baldera and Miguel Blay were indicted for the robbery that involved homicide and injuries, with Baldera receiving a sentence of death following court proceedings.
Legal Proceedings and Evidence
The procedural history reveals that four individuals were initially charged, with two defendants being dismissed due to insufficient evidence. Baldera and Blay were found guilty, with Baldera facing capital punishment. The case primarily hinged on the identification of Baldera as one of the perpetrators.
Identification of the Appellant
The prosecution presented testimonies from passengers who narrowly escaped the hold-up. Baldera was arrested shortly afterward for another crime, and he confessed to his involvement in the robbery after his apprehension. Ponciana Villena, a key witness, positively identified Baldera as the assailant threatening her for money. Baldera attempted to establish an alibi, claiming he was working elsewhere on the night of the crime; however, this was unsupported by any corroborating evidence.
Confession and Its Admissibility
Baldera's confession was contested on the grounds of coercion, with claims of a promise of immunity. However, the appellate court found no evidence of threats or coercion. The court had previously ruled that confessions obtained under promises could still be utilized if they did not involve force or intimidation. In this case, Baldera's participation in the robbery was deemed satisfactorily proven, independent of his confession.
Robbery in Band and Legal Definitions
The court also examined the classification of the crime as "robbery in band.” Despite Baldera's defense challenging the number of armed individuals involved, the evidence supported claims of more than three perpetrators. Nevertheless, the legal analysis indicated that the robbery could still be classified under robbery with homicide without necessarily fulfilling the criteria for being in band.
Verdict and Sentencing
The appellate court agreed with the conviction but acknowledged an error regarding the consideration of recidivism, as the previous theft occurred after the
...continue readingCase Syllabus (G.R. No. L-2390)
Case Overview
- The case involves Pedro Baldera, the defendant-appellant, who was sentenced to death for robbery in band with homicide and serious and less serious physical injuries.
- The events occurred on December 23, 1947, when a Casa Manila bus was held up by a group of armed men in the municipality of San Jose, Batangas.
- The court ruling was from the Court of First Instance of Batangas, which tried four defendants, leading to varying sentences.
Incident Details
- The robbery took place around 4 a.m. when the bus, laden with passengers, was ambushed.
- Pedro Baldera was identified as one of the armed men who fired shots during the hold-up.
- The shooting resulted in injuries to several passengers, including the death of Jose Cabrera the following day.
- Other injured passengers included Jose Pastor and Francisco Mendoza, who sustained serious but non-fatal injuries.
Court Proceedings and Charges
- Charges were levied against four individuals under the information of "robo en cuadrilla con homicidio y lesiones graves y lesiones merios graves."
- The case against two of the accused was dismissed due to lack of evidence.
- Pedro Baldera and his co-defendant Miguel Blay were found guilty, with Baldera receiving the death penalty for his action