Case Summary (G.R. No. L-17530)
Facts of the Case
The two accused planned a robbery at the home of Macario Conje. Upon entering the residence armed with bolos, the defendants attacked the family members—Macario Conje, Maximina Arreglado, Monina Conje, and Baby Conje. This unprovoked assault resulted in their instantaneous deaths. Santiaga Conje suffered injuries requiring medical attention. The attackers stole a trunk containing assorted clothing and a fighting cock, with the total value of the stolen items being P35.00.
Plea and Examination
Upon being formally charged, both defendants pleaded guilty to the crimes. During the sentencing phase, the trial judge conducted a thorough examination to ensure that the severity of the offense and its implications were fully understood by the accused. The defendants reaffirmed their plea and acknowledged the potential penalties they faced.
Trial Court's Decision
The trial court found the accused guilty beyond a reasonable doubt and imposed the death penalty. Although the defendants did not dispute the facts presented, they contested the appropriateness of the death penalty, believing reclusion perpetua to be more fitting due to several claimed mitigating factors.
Arguments on Penalty
The defendants-appellants argued that the trial court had erred by failing to consider intoxication and lack of education as mitigating circumstances. However, the court found no compelling evidence to suggest that the defendants were impaired by alcohol during the crime. Their claims regarding their alleged intoxication were insufficiently substantiated. Furthermore, the trial court ruled that lack of education does not serve as a mitigating factor in violent crimes such as homicide.
Assessment of Aggravating Circumstances
The court examined various aggravating circumstances present during the commission of the crime, such as nocturnity, treachery, evident premeditation, and the use of superior strength. It was determined that nocturnity should not be considered independently from treachery, as both were integral to the nature of the crime committed. The heinous and premeditated nature of the a
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Case Overview
- The case concerns a review of a decision made by the Court of First Instance of Masbate, presided over by Hon. Mariano V. Benedicto.
- The defendants, Causiano Enot and Pablo Vinalon, were sentenced to death for the crimes of robbery with multiple homicide and physical injuries.
- The defendants pleaded guilty to the charges brought against them, which included a detailed account of their criminal actions.
Facts of the Case
- The crime occurred on July 8, 1960, in San Jose, Cataingan, Masbate, where the accused entered the home of Macario Conje while he and his family were present.
- The defendants conspired to rob the household, armed with bolos, and attacked the occupants with deadly force.
- The victims included Macario Conje, his wife Maximina Arreglado, and their children Monina (a minor), Baby (7 months old), and Santiaga (5 years old).
- The attack resulted in the immediate deaths of Macario, Maximina, Monina, and Baby, while Santiaga sustained an injury requiring medical attention for 15 to 20 days.
Trial Proceedings
- Following their guilty plea, the trial judge questioned the defendants to ensure they understood the implications of their plea and the seriousness of the charges.
- The defendants confirmed their understanding, and their admissions during the examination solidified the court's findings.
- The trial judge n