Case Summary (G.R. No. L-30577)
Focus of the Crime and Investigation
The crime involved the unlawful taking of four carabaos and one cow from Maximiniano Cabangcala, who was shot by one of the robbers, Ben Bocasas. The police investigation culminated in October 1967 when Lauro Alcantara reportedly confessed to his involvement and named his accomplices, including Ricarte Obedoza. Alcantara’s confession indicated that he was present during the commission of the crime and identified Ambrocio Sumalbag as the mastermind behind the robbery.
Legal Proceedings and Charges
Following the investigation, a complaint for "Robbery in Band with Homicide" was filed on November 22, 1967, against the accused. By March 18, 1968, formal information was presented to the Court of First Instance of Nueva Ecija, detailing the roles of each accused in both the robbery and the homicide of Maximiniano Cabangcala.
Trial and Conviction
The trial proceeded with only a few of the accused being present, specifically Londring Martinez, Ambrocio Sumalbag, and Lauro Alcantara; the remaining accused were at large. On March 26, 1969, the trial court convicted these three individuals, sentencing them to life imprisonment, ordering them to indemnify the heirs of Cabangcala, and to cover the costs of the trial.
Prosecution's Evidence
The prosecution relied heavily on the confessions of Alcantara and Obedoza, which outlined the events of the robbery and identified the gunman. However, these confessions faced scrutiny regarding their admissibility and reliability, as they appeared to have been obtained under questionable circumstances, including alleged coercion.
Defense Claims
The defense presented alibis for the accused, suggesting they were elsewhere during the commission of the crime, and highlighted claims of coercion regarding the confessions. Alcantara argued he was tortured into confessing, and he contended he had no knowledge of the charges prior to his detention. Martinez and Sumalbag also maintained their innocence by providing their whereabouts on the night of the offense.
Critical Examination of Confessions
A significant point of contention arose around the confessions of Alcantara and Obedoza, as the trial court's reliance on these statements was challenged. The accused argued that the confessions were extracted under duress and that the police exerted forceful methods to secure admissions of guilt, undermining their voluntariness and validity as evidence.
Con
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Case Background
- The case arises from an incident that occurred on the night of May 28, 1967, in Barrio Salagusog, Cuyapo, Nueva Ecija.
- Victim Maximiniano Cabangcala, accompanied by his wife Isabel Dacanay and their two grandchildren, was assaulted by armed individuals who stole four carabaos and one cow.
- During the robbery, Maximiniano Cabangcala was shot in the leg, resulting in severe injuries leading to his death on June 13, 1967.
Incident Details
- The perpetrators were armed with firearms, and Maximiniano Cabangcala was hit by pellets from a .12 gauge shotgun as he attempted to escape.
- The stolen livestock was documented under certificates of ownership.
- The police investigation initially did not identify the culprits until a confession by Lauro Alcantara surfaced on October 24, 1967.
Confessions and Investigation
- Lauro Alcantara implicated several individuals, including Ben Bocasas as the shooter and Ambrocio Sumalbag as the informant regarding potential targets for theft.
- Ricarte Obedoza was also implicated by Alcantara and allegedly confessed his involvement in the crime.
- A complaint for "Robbery in Band with Homicide" was filed on November 22, 1967, against multiple accused, leading to the case being forwarded to the Court of First Instance of Nueva Ecija.
Trial Proceedings
- The trial commenced with only Londring Martinez, Ambrocio Sumalbag, and Lauro Alcantara being arraigned as the other accused remained at large.
- The prosecution's evidence consisted