Title
People vs. Lao
Case
G.R. No. L-10473
Decision Date
Jan 28, 1961
Rosario Lao and Alberto Padiamat conspired to murder Rosa Baltazar, with Padiamat executing the act; Supreme Court affirmed guilt, modified crime to murder, sentenced them to reclusion perpetua.
A

Case Summary (G.R. No. L-44351)

Charges and Proceedings

The Court of First Instance of Rizal, under the presiding Judge Hermogenes Caluag, found Rosario Lao and Alberto Padiamat guilty of the crime, sentencing each to reclusion perpetua (life imprisonment) and imposing a joint monetary indemnification of P6,000 to Rosa Baltazar’s heirs. Vicente Lao was acquitted, Osias Feliciano became a government witness, and Bienvenido Santos remained at large during the trial.

Background of the Crime

Rosario Lao and Vicente Lao’s relationship was complicated as he had another common-law wife, Rosa Baltazar, with whom he had two children. Rosa was reportedly brought to the poultry farm to assist Vicente in supervising the operations. Rosario expressed a desire to remove Rosa, citing bad fortune in their business arising from Rosa's presence. This set a context of animosity leading to the eventual plot to kidnap and murder Rosa Baltazar.

Kidnapping Execution

On December 7, 1953, a conspiracy unfolded involving Ben Santos and Padiamat, who during prior discussions with Mrs. Lao planned to take Rosa away. Osias Feliciano, who was present during these meetings, initially failed to disclose any knowledge of the plan but later admitted involvement. Rosa was taken under the pretense of carrying out a separate agenda during the night, leading to her abduction.

Discovering the Victim

The police were notified about Rosa’s disappearance on December 8, and her remains were eventually discovered on January 9, 1954. Autopsy findings confirmed the identity of the body, with evidence of foul play including injuries consistent with a violent death.

Confessions and Testimonies

Osias Feliciano’s testimony was critical, as he detailed the incidents surrounding the kidnapping, including conversations and exchanges among the conspirators. Padiamat, during the investigation, confessed to his role in the crime, detailing how Ben Santos orchestrated the kidnapping and subsequently conducted Rosa’s murder. His confession included how they planned the execution and buried the remains, further corroborating Feliciano's account.

Defense Claims

Alberto Padiamat’s defense argued that he merely assisted and did not actively participate in Rosa's murder, claiming that Santos was responsible for the physical act of killing. Nonetheless, the court found that the overall evidence indicated that Padiamat participated directly in the conspiracy and occurred in the abduction and burial of Rosa Baltazar, regardless of the nature of his involvement.

Court Findings

The trial court concluded that both Padiamat and Rosario Lao were integral to the commission of the murder. The crime was deemed murder, as it had been premeditated and executed w

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