Case Summary (G.R. No. L-8922-24)
Charges and Initial Ruling
The Court of First Instance of Camarines Sur found the defendants guilty of the charges and imposed sentences for each criminal case. Enguero was sentenced to an indeterminate penalty of 8 years and 21 days of prision mayor to 14 years, 10 months, and 21 days of reclusion temporal for each case, while the other three defendants received lesser sentences of 4 years and 2 months of prision correctional to 8 years and 21 days of prision mayor. The court also ordered restitution to the victims and recovery of various stolen items.
Appeal Process
Following sentencing, the defendants appealed their convictions. However, Jose Tariman later withdrew his appeal. The primary issue brought before the appellate court was whether the trial court erred in convicting the defendants of three separate robberies rather than a single offense of robbery in band. The Court of Appeals subsequently certified the case to the Supreme Court for further review.
Findings of the Lower Court
Evidence indicated that the defendants had collaborated in a series of robbery incidents. They began by meeting at Yabo River, after which they armed themselves with weapons, including a pistol and a bolo, and proceeded to commit acts of violence and intimidation against their victims. The defendants coerced numerous individuals into guiding them to various locations where they conducted multiple robberies, directly threatening victims with weapons.
Description of Criminal Acts
The defendants executed a well-orchestrated plan of robbery, first targeting the home of Cresenciano Magistrado, during which they physically restrained him, his family, and other Victims, leading to theft of multiple goods and cash. Following this, they proceeded to the residence of Anatolia Bragais and then to that of Florentina Ogarte, where they threatened and stole additional items. The total value of the stolen goods from all incidents amounted to substantial sums, aggravating the offenses.
Justification for Multiple Convictions
Counsel de oficio argued that the acts constituted a single crime of robbery; however, the Supreme Court found this argument unmeritorious. The Court indicated that the separate acts of robbery, conducted in different locations and against different victims, constituted distinct offenses punishable under the law.
Applicable Law and Sentencing Guidelines
The Supreme Court referenced Article 294, paragraph 5, of the Revis
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Case Overview
- The case involves four defendants: Florentino Enguero, Jose Tariman, Nazario Narvarte, and Dionisio Bueno, charged with the crime of robbery in band.
- The defendants were found guilty after a joint trial conducted by the Court of First Instance of Camarines Sur.
- The case was consolidated into three separate criminal cases (Criminal Case Nos. 2714, 2715, and 2716) with distinct acts of robbery.
Conviction and Sentences
- The court sentenced Florentino Enguero to an indeterminate penalty ranging from 8 years and 21 days of prision mayor to 14 years, 10 months, and 21 days of reclusion temporal for each of the three cases.
- Jose Tariman, Nazario Narvarte, and Dionisio Bueno were all sentenced to an indeterminate penalty ranging from 4 years and 2 months of prision correctional to 8 years and 21 days of prision mayor for each case.
- The defendants were ordered to indemnify various victims for the amounts of stolen goods and to pay costs associated with the trial.
Facts of the Case
- On July 9, 1952, at around 3:00 PM, the defendants convened at Yabo River, Lupi, Camarines Sur, with Florentino Enguero armed with a pistol.
- They proceeded to raid multiple residences, forcing individuals to guide them and tying their ha