Case Summary (G.R. No. 6516)
Facts of the Case
During the described incident, the four assailants requested water from the occupants, after which they violently attacked them, leading to physical injuries for Benita Manuel and the theft of a locked trunk containing money and valuables. The assailants were later apprehended, and following a trial, the Court of First Instance of Ilocos Sur convicted the five defendants of robbery (robo en cuadrilla) and imposed a sentence of eight years and one day of presidio mayor along with accessory penalties and restitution.
Legal Classification of the Crime
The court determined that the crime constituted robbery as defined under articles 502 and 503, No. 5 of the Penal Code. The evidence showed that the assailants assaulted the dwelling during the owners' absence, inflicted harm on the victims, and took the property outside to be hidden, which fulfilled the statutory requirements for robbery.
Findings on Robbery En Cuadrilla
The court ultimately ruled against classifying the crime as robbery en cuadrilla because it was not established that more than one of the defendants was armed. The requirement under Article 505 calls for at least four armed individuals, which was not met as only one assailant was observed wielding a stick.
Injuries Inflicted and Their Legal Classification
The injuries sustained by Benita Manuel were classified as lesiones menos graves (less grave injuries), which influenced the severity of the charges. A medical examination confirmed these injuries and established that she suffered from a broken forearm and other physical trauma.
Evidence Against the Defendants
Despite claims of innocence from some defendants, the court found confessions made by Lucas Villaros and Proceso Ramos to municipal authorities compelling, alongside their identification by Ruperta Longino. The lack of evidence supporting claims of maltreatment during these confessions led the court to deem them valid and voluntary.
Weight of Confessions and Identification
The credibility of the confessions was further bolstered by the absence of physical evidence contradicting their validity. Moreover, jewelry identified as stolen was discovered in Barroga's possession, affirming his involvement in the crime. The court stated that complaints pertaining to maltreatment were not sufficiently supported and highlighted the voluntary nature of their admissions.
Acquittal of Certain Defendants
In contrast, the court found insufficient evidence to implicate defendants Pedro Alisias and Lucas Barroga. Alisias' involvement was primarily based on circumstantial evidence, while Barroga's alleged confession did not implicate him adequately in the crime, nor
...continue readingCase Syllabus (G.R. No. 6516)
Case Background
- The case involves an appeal by five defendants from a judgment of conviction rendered by Judge Dionisio Chanco.
- The incident occurred on the evening of March 27, 1910, when four men assaulted the home of Basilio Longino and Leona Fontano in Vigan, Ilocos Sur.
- At the time of the assault, the homeowners were absent, leaving their 13-year-old daughter Ruperta Longino and her grandmother Benita Manuel in the house.
Details of the Assault
- The assailants initially requested water, and upon receiving it, one of them threw the water into the fireplace and extinguished the light.
- Benita Manuel confronted the intruders, resulting in her being physically assaulted, including being struck and choked, while Ruperta was blindfolded.
- The robbers took a locked trunk belonging to Leona Fontano, which contained P42 in cash and jewelry worth approximately P100. The trunk was later found broken open in a nearby vegetable garden.
Impact on Victims
- Benita Manuel suffered serious injuries, including a broken forearm, chest bruising, and a swollen head.
- She was unable to work for 30 days due to her injuries, which were classified as "lesiones menos graves" by a physician.
Charges and Initial Court Proceedings
- A complaint was filed against the five defendants for the crime of "robo en cuadrill