Case Summary (G.R. No. L-4158)
Factual Background
At about midnight on April twenty-four, nineteen hundred seven, the defendants, armed with bolos, forcibly entered the house of Francisco Darapisa in the barrio of Manaoag, Pangasinan. They were accompanied by several others who did not enter the house.
Upon entry, the defendants ordered Darapisa to lie face down on the floor. Darapisa refused. When the defendants attacked him, he seized his bolo and wounded one of the attacking party in the breast. He was then compelled to flee through the window, pursued by the band.
Darapisa’s wife was in the room during the attack. She escaped to a neighbor’s house nearby and remained there until the robbers later returned to the house and finally departed. When she returned, she found that the robbers had rifled her trunk and taken P7. The neighbors who accompanied her later located Darapisa’s dead body about thirty yards away in a canebrake.
The body bore fourteen wounds inflicted with sharp instruments. Half of the wounds were of a fatal character. Some were stabs in the body and others were cuts on the side of the head.
Trial Court Disposition
The trial court treated the offense as robo con homicidio marked by the aggravating circumstances that the crime was committed by an armed band at night and in the victim’s dwelling house, and it found that there were no extenuating circumstances. Accordingly, it imposed the death sentence on all perpetrators except Narciso Centeno, who was sentenced to cadena perpetua (life imprisonment). Centeno did not appeal, and the record as to the others was before the Court en consulta.
The Issue on Appeal: Identity of the Accused
Counsel for the defense relied chiefly on the alleged failure of the prosecution to prove the identity of the defendants with the perpetrators of the crime. The principal question before the Court was whether the evidence established beyond a reasonable doubt that the accused were the same persons who participated in the robbery and the killing.
Evidence Supporting Identity
The Court relied on the testimony of the widow of the murdered man. The Court described her as an intelligent witness. She identified each of the defendants as members of the band who entered her house on the night of the robbery. She stated that, although she did not know any of them prior to that night, she saw them distinctly by the light of a lamp. She further testified that the faces of the robbers were so distinctly impressed on her memory that she could not be mistaken.
The Court also noted an incident that occurred during the testimony. With the permission of the court and without the knowledge of the witness, the defense withdrew one defendant and substituted in his stead another prisoner from the provincial jail. The substitute was dressed in similar clothing and resembled the withdrawn defendant in height, weight, and general appearance. The widow promptly recognized the newcomer and pointed him out among the other prisoners. While the Court did not treat this as conclusive proof, it considered it indicative of the witness’s alertness of mind and intelligence, and it found that the trial judge was strongly impressed by her testimony.
As to Narciso Centeno, the Court observed that he had been arrested on suspicion and had confessed his guilt while giving the names of the other defendants as participants. The Court held that the trial court properly declined to consider the evidence of Centeno’s confession except against Centeno himself.
Corroborative Circumstances and Conduct Indicative of Guilt
The Court treated additional circumstances as corroborative of the widow’s identification. Two witnesses testified that at daybreak, the morning after the night of the crime, they saw Isidro Valenzuela and Daniel de Guzman—two of the accused—carrying something in a hammock in the road. Another witness later saw these same persons carrying Mateo Carino in a hammock into the house of Gabriel Valenzuela.
At that place, Mateo Carino was later found rolled in a blanket with a fresh wound in his breast consistent with a bolo wound. He attempted to prevent his captors from opening the blanket to examine the wound. When concealment failed, he stated that the wound had been caused by a bamboo with which he claimed he had cut himself the day before.
The Court further noted the recovery of weapons. The bolo of the deceased was found concealed in the grass near the house of Gabriel Valenzuela. Three other bolos, smeared with fresh blood, and a spear with a short handle were found concealed in a corner of the back yard of Jose Valenzuela.
The Court also took into account the clothing of the robbers. The widow testified that the robbers were dressed in bl
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Case Syllabus (G.R. No. L-4158)
- The defendants, Mateo Carino, Gabriel Valenzuela, Daniel de Guzman, Jose Valenzuela, Isidro Valenzuela, and Narciso Centeno, were charged for their participation in a fatal robbery committed in the barrio of Manaoag, Pangasinan.
- The Court rendered a decision in a case that proceeded en consulta, with Narciso Centeno having been sentenced to cadena perpetua and not having appealed.
Key Factual Allegations
- About midnight on April 24, 1907, the defendants, armed with bolos, forced their way into the house of Francisco Darapisa.
- The entering group included the six defendants, while “several others” remained outside the house.
- The defendants ordered Darapisa to lie face down on the floor, and upon his refusal they attacked him.
- Darapisa seized his bolo and wounded one of the attackers in the breast before fleeing through a window.
- Darapisa was later found dead about thirty yards away in a canebrake.
- There were fourteen wounds on the body, inflicted with sharp instruments, with about half being fatal wounds, including stabs to the body and cuts on the side of the head.
- While the attack was ongoing, the victim’s wife escaped to a neighbor’s house and remained there until the robbers later returned and then departed.
- After her return, the wife found that the robbers had rifled her trunk and taken P7.
- The evidence showed that the robbers dressed in black police uniform clothing except one who wore white trousers, and the defendants were previously rural guards whose uniform color was described as dark-blue.
- At daybreak after the crime, witnesses saw Isidro Valenzuela and Daniel de Guzman carrying something in a hammock in the road.
- Other testimony stated that these same persons later carried Mateo Carino into the house of Gabriel Valenzuela using a hammock.
- Mateo Carino was later found rolled in a blanket with a fresh wound in his breast resembling a bolo wound.
- Mateo Carino attempted to prevent his captors from opening the blanket to examine the wound, and when he could not conceal it, claimed it resulted from a bamboo injury the day before.
- The bolo of the deceased was found concealed in the grass near Gabriel Valenzuela’s house.
- Three other bolos smeared with fresh blood, and a spear with a short handle, were found concealed in a corner of Jose Valenzuela’s back yard.
- The defense raised an alibi, but the evidence presented to support it was characterized as not convincing and insufficient to raise a reasonable doubt.
Charges and Trial Court Result
- The offense proved at trial was robo con homicidio (robbery with homicide).
- The Court treated the robbery as attended by aggravating circumstances including commission by an “armed band”, at night, and in the dwelling house of the victim.
- The trial court found no extenuating circumstances and therefore imposed the death sentence on the perpetrators.
- The trial court imposed cadena perpetua (life imprisonment) on Narciso Centeno.
- The record as to the others was submitted to the Court en consulta.
Issues Framed
- The defense argued that the prosecution failed to prove the identity of the defendants as the perpetrators of the crime.
- The case turned on whether the evidence established guilt b