G.R. No. 11562 - People vs Lazaro

A witness's prior inconsistent statements made shortly after a crime do not automatically discredit their testimony if such inconsistencies are satisfactorily explained.
The trial judge possesses unique advantages in assessing the credibility of witnesses, and the Supreme Court will not overturn the trial court's judgment on credibility unless significant facts or circumstances have been overlooked or misinterpreted.

For a defendant to be punished under paragraph 3 of Article 503 in relation to Article 504 of the Penal Code for robbery in a band with serious physical injuries, the complaint must demonstrate that the injuries resulted in the loss of a principal member or the use thereof.

The defendants, Simon Lazaro, Juan Lazaro, and Francisco Manzano, were convicted of robbery in a band with serious physical injuries and sentenced to nineteen years, one month, and eleven days of cadena temporal, along with accessory penalties and indemnification to the victim, Catalina Madrazo.
The defendants appealed, arguing errors in the trial court's findings regarding their guilt, the classification of the crime, the nature of the injuries inflicted, the presence of aggravating circumstances, and the imposed penalty.

On the night of August 20, 1915, a group of at least seventeen armed men attacked Catalina Madrazo's home, demanding money and inflicting injuries on her and her granddaughter, Maura Lomboy.
The victims were coerced into handing over significant amounts of money, and a bystander, Inocencio Alberto, was severely injured while attempting to assist.

Catalina Madrazo and her granddaughter Maura Lomboy provided testimonies detailing the robbery, including the demands for money and the physical assaults they endured.
Maura initially claimed she did not recognize the robbers due to fear, but later identified Simon and Juan Lazaro as the assailants.
Jorge Galang, who witnessed the events from a hiding place, also identified the Lazaro brothers after the robbery.

The defense presented testimonies from municipal policemen who stated that the victims did not recognize the robbers immediately after the incident.
The defendants claimed they were wrongfully accused and provided alibis, asserting that they had no involvement in the robbery.

The court found that Maura Lomboy was in a position to recognize the robbers, as they lit a lamp and spent several minutes in her presence.
The inconsistencies in her initial statements were attributed to the trauma of the event rather than a lack of recognition.
The corroborative testimonies from other witnesses supported the prosecution's case, leading the court to uphold the trial court's findings.

The trial court classified the crime under paragraph 3 of Article 503, which requires that serious physical injuries result in the loss of a principal member or its use.
The court noted that while Inocencio Alberto suffered a grave woun...continue reading