Case Summary (G.R. No. 40331)
Case Background
The appellants, Silverio Daos, Dominador Sablada, and Gerardo Bacabizas, were charged with the crime of robbery with homicide, resulting from a premeditated attack on Felino Dumalo, who was a chauffeur for a taxi company. The trial court convicted the appellants and sentenced them to death, along with indemnifying Dumalo's heirs and covering the costs of prosecution. The case centers on the contention that the trial court committed errors in declaring guilt for robbery with homicide instead of simple murder, imposing the death penalty, and neglecting to consider mitigating circumstances.
Evidence and Confessions
At approximately 4 PM on June 7, 1933, Felino Dumalo's lifeless body was discovered inside a taxi at a secluded location in San Juan del Monte, Rizal. An autopsy conducted by Dr. Pablo Anzures revealed multiple injuries, indicative of death by asphyxia through strangulation. The appellants admitted to their involvement in the crime during their arrests, with Dominador Sablada being the first to confess to authorities about the plan to kill Dumalo and rob him of his money, a narrative corroborated by all three appellants at various stages of their detention.
Criminal Conspiracy
Testimonies indicated a conspiratorial agreement among the appellants, where they intended to deceive Dumalo into thinking they were legitimate passengers. They executed their robbery and homicide by attacking him from behind and strangling him, then subsequently dividing the stolen money among themselves. Each appellant placed himself at the crime scene, admitting varying degrees of responsibility while simultaneously attempting to reduce their individual culpability.
Denials and Allegations of Coercion
During the trial, the appellants attempted to retract their confessions, alleging they were forced to confess under duress, including physical abuse during interrogation. However, testimonies from law enforcement officials stated that the confessions were made voluntarily and in a calm state, countering claims of maltreatment. Moreover, corroborating evidence from witnesses demonstrated the appellants' presence and actions both during and after the crime, further undermining their claims of coercion.
Determination of Guilt
The court found that the combined evidence—confessions, witness testimonies, and forensic analysis—strongly supported the prosecution's case against the appellants for robbery with homicide, stating that their collective actions constituted a conspiracy aimed at committing the dual crimes. The aggravating circumstances of craft and
...continue readingCase Syllabus (G.R. No. 40331)
Case Background
- The defendants were charged with robbery with homicide and were convicted, resulting in a death sentence.
- The trial court also ordered them to indemnify the victim's heirs and cover the prosecution costs.
- The defendants appealed, asserting three main errors by the trial court:
- Incorrect conviction of robbery with homicide instead of simple murder.
- Improper imposition of the death penalty instead of a lesser penalty.
- Failure to consider mitigating circumstances of passion and obfuscation.
Facts of the Case
- The victim, Felino Dumalo, a chauffeur, was found dead in a taxi on June 7, 1933, in San Juan del Monte, Rizal.
- An autopsy revealed severe injuries consistent with strangulation, including:
- Ligature marks on the neck.
- Multiple bruises and abrasions.
- Hemorrhage in the cornea of the right eye and other internal injuries.
- The cause of death was determined to be asphyxia due to strangulation.
Defendants' Actions and Confessions
- The defendants had a premeditated plan to rob the taxi driver, Dumalo, while pretending to be passengers.
- Sablada initiated the confession shortly after his arrest, detailing how they attacked Dumalo from the back seat and strangled him.
- Bacarizas was also arrested shortly after, admitting to the crime and confirming Sablada's confession.
- Dao