Case Summary (G.R. No. L-27758)
Summary of Charges
The case revolves around the defendants, who were charged with robbery with homicide for conspiring to violently enter the residence of Carlota P. Ocenada in Calbiga, Samar. Armed with guns and a knife, they demanded money, resulting in the death of Pablo Ocenada, who was stabbed multiple times during the attack. The total amount stolen amounted to P535, which included P135 found in a trunk and P400 from a suitcase.
Circumstantial Factors
The trial court identified several aggravating circumstances in its decision. These included:
- Nighttime, which exacerbated the fear and potential for violence during the crime.
- The act being committed in the dwelling of the victims, who did not provoke the attack.
- The defendants' prior conviction for murder, suggesting a pattern of violent behavior.
- Evident premeditation, indicating that the defendants planned the crime beforehand.
- Abuse of superior strength, given their armed status and number advantage over the victims.
Court Proceedings and Plea
During arraignment, all three defendants expressed their intent to plead guilty. Each was asked multiple questions to ensure understanding of the implications of their plea, which included potential sentences ranging from imprisonment to death. Despite acknowledgment of these consequences, they reaffirmed their guilty plea, indicating a recognition of the crime's gravity.
Judgment and Sentencing
The lower court ultimately convicted the defendants based on their guilty plea and the presence of aggravating factors, sentencing them to death and requiring them to indemnify the victims' heirs. This included compensation for the stolen funds and additional damages to the heirs of Pablo Ocenada in the amount of P6,000.
Review on Appeal
On appeal, the court examined arguments regarding the aggravating circumstances, particularly reiteration and premeditation. The defense contested the inclusion of these factors, citing the need for previous sentences to have been served for reiteration to be applicable, and questioning whether night conditions were deliberately exploited. However, the court found that evident premeditation to commit homicide was inherent to the case of robbery with homicide.
Conclusion of the Review
The court affirm
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Case Overview
- This case involves an automatic review of a decision made by the Court of First Instance of Samar, which convicted the defendants, Demetrio Nabual, Luis Nabual, and Elpidio Bachicha, of robbery with homicide.
- The incident occurred on January 7, 1967, in Calbiga, Samar.
- The defendants were charged with entering the residence of Carlota P. Ocenada, demanding money while armed, and ultimately killing her husband, Pablo Ocenada.
Crime Details
- The defendants entered the victim's home armed with guns and a knife.
- They threatened Carlota P. Ocenada, demanding money, which she provided out of fear for her life.
- The total amount stolen was P535, consisting of P135 from a trunk and P400 from a suitcase.
- Pablo Ocenada was attacked and stabbed multiple times, leading to his death as a result of the inflicted wounds.
Aggravating Circumstances
- The trial court noted several aggravating circumstances during the commission of the crime:
- Nighttime: The crime was committed under cover of darkness.
- Dwelling: The crime took place in the home of the victims, who had not provoked the attack.
- Habituality: The defendants had a prior conviction for murder, indicating a pattern of criminal behavior.
- Evident Premeditation: The planning involved in both the robbery and the intent to kill was evident.
- Abuse of Superior Strength: The defendants used their numbers and weapons to overpower the victims.