Case Summary (G.R. No. 126126)
Charges and Allegations
The accused were charged with robbery with homicide, as defined under Article 294, paragraph 1 of the Revised Penal Code, along with illegal possession of firearms as stipulated in Presidential Decree No. 1866. The circumstances of the case involved armed individuals forcibly taking money and firearms at the Rizal Commercial Banking Corporation while fatally wounding both a police officer and a bank security guard.
Proceedings and Trial Court’s Findings
Upon arraignment, Sales Sabadao and Vidal Valdez pleaded not guilty to all charges. The trial court's proceedings included testimonies from bank employees, police officers, and the medical examiner. The trial court ultimately found both accused guilty beyond reasonable doubt of robbery with homicide and illegal possession of a firearm, sentencing them to reclusion perpetua and ordering them to pay damages to the victims' heirs.
Key Evidence and Testimonies
The prosecution presented numerous witnesses, including bank security guards and employees, detailing the robbery's execution and the ensuing violence. Eyewitness accounts corroborated the claims of active involvement by the accused in both the robbery and the shootings of the victims. Notably, testimonies established that the malefactors had a premeditated plan and executed their scheme in a coordinated manner, culminating in fatalities.
Defense Claims
In their defense, the accused-appellants introduced alibi arguments. Vidal Valdez asserted he was at the bank for a legitimate reason, while Sales Sabadao claimed he was not present at the robbery site. However, the trial court found these defenses insufficient to create reasonable doubt about their involvement.
Trial Court’s Conclusion and Sentencing
The trial court determined that there was a conspiracy among the accused, which facilitated the execution of the robbery. It acknowledged that, despite the separate actions leading to the deaths of the police officer and the security guard, all parties were complicit in the overarching crime of robbery with homicide. Both accused were found guilty as charged, receiving sentences of reclusion perpetua.
Appellate Review and Modifications
Upon appeal, the court ruled in favor of maintaining the conviction for robbery with homicide but found that the lower court improperly applied the law regarding the illegal possession of firearms. It referenced Republic Act No. 8294, which redefined the consequences of using unlicensed firearms in the commission of other crimes. As a res
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Case Background
- This case involves an appeal from the joint Decision dated July 21, 1995, of the Regional Trial Court of Batac, Ilocos Norte, Branch 18.
- The case numbers include Criminal Case No. 2547-18 for robbery with homicide and Criminal Case Nos. 2548-18 and 2549-18 for illegal possession of firearms and ammunition.
- Accused-appellants Sales Sabadao and Vidal Valdez were found guilty beyond reasonable doubt of robbery with homicide and illegal possession of firearms.
- The trial court sentenced both accused-appellants to suffer the penalty of reclusion perpetua and ordered them to pay actual and moral damages to the heirs of the victims.
Charges and Allegations
- The information in Criminal Case No. 2547 alleges that on June 23, 1987, the accused conspired to rob the Rizal Commercial Banking Corporation in Batac, Ilocos Norte.
- The robbery involved the use of intimidation and violence, with the accused armed with unlicensed firearms, resulting in the deaths of Security Guard Romeo Aganon and Pfc. Arnulfo Valera.
- Additional charges against Vidal Valdez and Sales Sabadao involved illegal possession of firearms in Criminal Cases Nos. 2548 and 2549, respectively.
Proceedings and Evidence
- Upon arraignment, both accused pleaded not guilty.
- The prosecution presented nine witnesses, including bank employees and police officers, detailing the events of the robbery.
- Testimonies indic