Title
People vs Bagsic
Case
G.R. No. 11042
Decision Date
Nov 18, 1916
An 80-year-old man was robbed and assaulted in 1915; defendants' alibis were dismissed, and accomplice testimony led to their conviction for robbery with violence, with penalties adjusted for nocturnity.

Case Summary (G.R. No. 11042)

Complaint and Initial Proceedings

The provincial fiscal charged the defendants with robbery committed against Juan de Ocampo, who, on the night of January 15, was assaulted and subsequently robbed of his money amounting to P150.30. The complaint specified that the assault involved striking Ocampo on the head with a club, leading to his unconsciousness and the unlawful seizure of his money. Following their arraignment, the defendants pleaded not guilty. The trial commenced shortly thereafter, wherein both the prosecution and defense presented their evidence.

Trial Court Judgment

On May 13, 1915, the Court of First Instance found the defendants guilty of robbery with violence, taking into account the aggravating circumstance of nocturnity. Each defendant was sentenced to 12 years and 1 day of cadena temporal, along with accessory penalties. The court ordered the defendants to return the stolen money to Ocampo and to share the costs of the trial equally.

Appeal by Defendants

The defendants appealed the judgment on two grounds: first, that the trial court erred in denying their motion to dismiss based on insufficient evidence, and second, that the court wrongfully held them guilty of the crime charged. The appeal brought into question the sufficiency of the evidence presented at trial.

Evidence Presented

The prosecution's case was bolstered by witness testimonies, including those of Basilio Gamboa, Sixto Gamboa, and Clemente Caballero, who confirmed witnessing the events leading to the assault. They testified that the defendants conspired and coordinated to ambush Juan de Ocampo based on prior knowledge of the money he was carrying. The psychological and physical aftermath for Ocampo, including the injury to his ear and his weakened state following the assault, were also highlighted.

Defense and Alibi Claims

The defense argued that the defendants provided alibis that contradicted the prosecution's timeline. They claimed to have been involved in social gatherings at another location and thus could not have participated in the robbery. However, the court found inconsistencies in their alibi, particularly in the testimony from their witnesses regarding the timing and nature of the events during the social gathering, which undermined the credibility of their claims.

Examination of Alibi Credibility

Witness testimony during the trial raised several doubts about the defendants’ alibis. Although some witnesses testified to their presence at a gathering, none could definitively confirm their absence from the area of the crime. A critical assessment of distances and witness locations indicated that it would have been feasible for the defendants to commit the robbery and return shortly after.

Admissibility and Impact of Accomplices' Testimony

The Court recognized the admissibility of accomplice testimony, asserting that such testimonies can establish culpability even without corroborating evidence, provided they are credible. The trial court had appropriately considered the testimonies of accomplices who directly described the participation of the defendants in the commission of the robbery.

Conclusion and Sentence Modification

The appellate court reviewed the evidence af

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