Title
People vs. Pelagio y Alfonso
Case
G.R. No. L-16177
Decision Date
May 24, 1967
A group planned and executed a robbery, resulting in a homicide. Defendants faced charges; Caymo convicted of robbery with homicide, Pelagio of simple robbery, and Guico acquitted due to minimal involvement.

Case Summary (G.R. No. L-16177)

Background of the Crime

The robbery was plotted by the defendants and involved a plan to rob a residence belonging to a former landlady of one of the conspirators. Initially, six individuals were named in the complaint; however, two co-defendants, Arcadio Balmeo and Evelyn Villanueva, were discharged when they agreed to testify for the prosecution. The robbery plan was finalized during meetings at the residences of Jose Guico and Evelyn Villanueva, before proceeding to execute the robbery.

Execution of the Robbery

On March 24, 1955, the conspirators, minus Jose Guico who was allegedly showering, proceeded to the victim’s residence. Pancho Pelagio acted as a lookout while Caymo and Balmeo entered the house, where they confronted the occupant, Mrs. Severina de Gloria, and demanded money and jewelry. After robbing the victim, a violent confrontation ensued when the conspirators encountered a police officer, Patrolman Francisco Trinidad, resulting in his death when Caymo fired several shots.

Arrest and Subsequent Confessions

The perpetrators were arrested shortly after the incident. Oscar Caymo was found to have gunpowder residue on his hands, and subsequently, he made an extrajudicial confession implicating the others. Jose Guico also confessed his involvement, while Armando Manalang confessed later, further confirming the conspiracy.

Defense Strategy of the Appellants

During the trial, the main defense presented by the appellants was alibi, asserting that they were not present during the commission of the crime. However, the evidence against them was significant, including eyewitness accounts and forensic evidence. Notably, Caymo maintained his alibi throughout the appeal process.

Court's Findings on Appellant's Guilt

The appellate court found Oscar Caymo guilty beyond reasonable doubt of robbery with homicide, affirming the lower court's decision. The court dismissed Caymo's defense of alibi, as multiple witnesses identified him as one of the robbers and the shooter, thereby fulfilling the standards for establishing his guilt.

Modification of Pancho Pelagio’s Liability

The court found sufficient grounds to reduce Pancho Pelagio’s conviction from robbery with homicide to simple robbery. The court noted that he was not present when the vital crime of homicide occurred and thus could not be held culpable for the death of Patrolman Trinidad. Although he participated in the robbery, evidence suggested that he fled prior to the murder, clearing him of complicity in the homicide.

Acquittal of Jose Guico

The court agreed with the recommendation from the Office of the Solicitor General to acquit Jose Guico due to insufficient evidence conn

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