Case Summary (G.R. No. L-32562)
Charges and Court Proceedings
The defendants faced two charges: Robbery (CCC-VI-627) and Robbery with Homicide (CCC-VI-628). The Circuit Criminal Court of Manila found Cristobal, Duncil, and Valerio guilty of theft leading to Villanueva’s death, while Pagaduan's guilt was noted after he changed his plea. The court sentenced Cristobal, Duncil, and Valerio to death but later modified the imposed penalty to reclusion perpetua on appeal due to a lack of unanimous votes for the death penalty.
Activities Leading to the Crime
The events unfolded as the accused planned a robbery after a drinking session. They boarded a passenger jeepney with the intention of staging a hold-up. The operation turned violent when Villanueva resisted their attempts to steal his watch, leading to his stabbing by Cristobal. Fernandez witnessed the assault.
Eyewitness Testimony
Mario Fernandez and Melquiades San Jose, the jeepney driver, provided critical testimony regarding the robbery and murder. Fernandez described how Valerio attempted to restrain Villanueva, while Cristobal stabbed the victim. The witnesses' accounts were corroborated by the rapid sequence of events, despite some minor inconsistencies.
Investigative Findings
Following the crime, police apprehended Duncil and Pagaduan after spotting them attempting to evade capture. Blood-stained clothing was found on Duncil, and Pagaduan was found with an Omega wristwatch claimed by Fernandez as his own. This led to further investigations and the eventual capture of Cristobal, who confessed to his involvement and identified the watch he had stolen.
Defense Claims
The defense argued against the validity of the evidence, including confessions made by the accused. They contended that the confessions were coerced and denied that the Seiko watch belonged to Villanueva. Each defendant attempted to distance themselves from the major acts of violence while asserting that they acted individually without a cohesive plan; however, the prosecution demonstrated a clear conspiracy.
Legal Principles Applied
The trial court established that conspiracy amongst the accused existed, warranting shared liability. In custodial situations, each accused's actions during the robbery led to serious outcomes, forming a basis for the classification of the crime as robbery with homicide under Philippine law.
Evaluation of Aggravating Circumstances
The court considered several aggravating factors such as the presence of craft and nighttime. However, the court corrected its initial consideration of nighttime as an aggravating circumstance, determining that the robbery was not premeditated to take advantage of darkness, especially since the crime occurred in a we
...continue readingCase Syllabus (G.R. No. L-32562)
Case Overview
- The case involves an automatic review of the decision rendered by the Circuit Criminal Court of Manila, which imposed the death penalty on the accused: Aurelio Cristobal, Jr., Vicente Duncil, and Florentino Valerio, Jr.
- They were found guilty of robbery with homicide, with aggravating circumstances of nighttime, abuse of superior strength, and craft, and without any mitigating circumstances to offset these.
Incident Details
- The incident occurred on December 23, 1969, around 1:00 AM, when a hold-up took place inside a passenger jeepney en route from Malabon to Sta. Cruz.
- Dominador Villanueva, a special police officer, was stabbed and killed during the robbery, while another passenger, Mario Fernandez, sustained a chest wound.
Eyewitness Accounts
- Mario Fernandez, a passenger, recounted the events leading to the robbery:
- He entered the jeepney with Villanueva as the sole other passenger.
- The accused entered the vehicle shortly after.
- A commotion ensued when Duncil attempted to grab Villanueva's watch, leading to Cristobal stabbing Villanueva.
- Fernandez was also attacked, resulting in injuries to his chest.
- The jeepney driver, Melquiades San Jose, corroborated the testimony, indicating that Valerio acted suspiciously and attempted to assist in the robbery by physically restraining Villanueva.
Arrest and Investigation
- Following the incident, police apprehended Duncil and Pagaduan based on suspicious behavior observed at the scene.
- Duncil was found wearing a bloodstained shirt, and Pagaduan possessed a wrist