Case Summary (G.R. No. L-37937)
Applicable Law
The case is decided under the Revised Penal Code regarding the crime of robbery with homicide and the relevant provisions governing the imposition of penalties. As the decision is post-1987, the provisions of the 1987 Philippine Constitution are applicable.
Facts of the Case
The incident began around 9:00 AM on April 6, 1973, when the accused planned to rob a Caltex gasoline station. On the night of the robbery, Natividad Pacheco, the proprietor, and her driver, Vito Robles, were waiting for a jeepney and carrying cash amounting to P830. The accused boarded the same jeepney, and as it moved, they announced a holdup, during which Vallente attempted to grab the money from Pacheco while Robles intervened, leading to a fatal confrontation.
Trial Court's Decision
The trial court convicted Vallente and several co-accused of robbery with homicide, sentencing Vallente and others to death, while one co-accused received a life sentence, and some were acquitted due to lack of evidence. Notably, after the trial, two co-accused facing the death penalty died under circumstances unrelated to the trial, prompting a review of their cases.
Appeals and Contentions
Vallente's defense argued several points, including that the crime constituted only an attempted robbery and that he should not be treated as a principal in the homicide. The appeal included claims of erroneous appreciation of aggravating circumstances and disparities in sentencing provisions between co-accused.
Court's Analysis of the Evidence
The Supreme Court assessed the validity of the trial court’s decision by confirming that the evidence presented supported the conclusion of a consummated robbery with homicide. The testimonies, particularly that of Natividad Pacheco and co-conspirator Dantes, were deemed sufficient to establish Vallente's active participation in the crime, countering his defense's claims.
Liability for Homicide
The Court reiterated that all participants in a robbery share liability for any resultant homicide, especially when armed with weapons, confirming Vallente’s involvement in the violent confrontation that resulted in Robles' death. The Court emphasized that all members of the criminal conspiracy are collectively responsible, notwithstanding individual roles.
Aggravating Circumstances
The Supreme Court upheld the trial court's findings of aggravating circumstances, such as craft and abuse of superior strength, noting that the pretense of being jeepney passengers facilitated their plan to commit robbery. This consideration contributed to the characterization of their actions as particularly heinous.
Sentencing Discrepancies
The appellate court addressed Vallente's contention regarding
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Case Overview
- The case involves a criminal charge against Mauro Vallente and several co-accused for the crime of robbery with homicide.
- The information was filed on April 11, 1973, in the Circuit Criminal Court of Manila.
- The incident occurred on April 7, 1973, in Manila, where the accused, armed and in conspiracy, committed the robbery resulting in the death of Vito Robles.
Allegations and Charges
- The accused conspired to rob Natividad Pacheco while she was in a passenger jeepney.
- They forcibly took P830.00 from Pacheco and assaulted her companion, Vito Robles, leading to his death via gunshot wound inflicted by one of the accused.
- The crime was classified as robbery with homicide due to the violent actions taken during the commission of the robbery.
Initial Trial and Judgment
- The trial court rendered a decision on August 23, 1973, convicting some of the accused while acquitting others based on the evidence presented.
- The court sentenced:
- Reynaldo Dantes, Mauro Vallente, and Rodolfo Balinas to death due to aggravating circumstances.
- Carlos Medina to life imprisonment without aggravating or mitigating circumstances.
- Indemnity amounts were stipulated for the heirs of the deceased and the victim of the robbery.
Review of the Decision
- The decision was automatically reviewed by the Supreme Court due to the death penalty imposed.
- Mauro Vallente escaped from custody in 1974 but the review proceeded to determine the appropriateness of his sentence.
- The court noted t