Case Summary (G.R. No. 10174)
Proceedings and Initial Judgment
During the initial proceedings, the defendants were arraigned and pleaded not guilty. Lorenzo Reyes was later excluded from the charge to serve as a witness for the prosecution. On July 31, 1914, the Court of First Instance found Perez, De Leon, and Manago guilty of robbery with murder, considering the aggravating circumstances of treachery, nocturnity, unlawful entry, and unusual cruelty, leading to a sentence of death alongside civil liabilities.
Appeals and Allegations of Error
The defendants appealed the conviction, arguing that the trial court erred in concluding their guilt beyond a reasonable doubt and in the characterization of the crime as robbery with murder rather than robbery independently of murder. The Supreme Court undertook a thorough review of the evidence presented.
Evidence of Guilt
The prosecution presented compelling evidence confirming the defendants' culpability. Testimonies from Miguela Sibug, the widow of the deceased, described the violent actions of the defendants, establishing their roles and the timeline of events. Witness accounts detailed the assault on Damaso Valencia by the armed group, evidenced by the examination of the deceased, who bore numerous fatal wounds.
Role of Lorenzo Reyes
Lorenzo Reyes, initially one of the accused, later testified against the others. Despite being an accomplice, his testimony significantly corroborated Miguela Sibug's account and the involvement of the other defendants. The court noted that his evidence still bore credibility and aligned with witness statements about the sequence of events leading to the murder and robbery.
Admission of Guilt
Confessions from Faustino Manago during interrogation further reinforced the prosecution's case. He acknowledged participation in the assault and the robbery, implicating the others in the crime. The court considered this confession credible and linked it to the role of the defendants, affirming the presence of both murder and robbery in the commission of the crime.
Alibi Defense
The defense attempted to establish an alibi, with witnesses asserting that Abdon de Leon and Faustino Manago were in Hagonoy at the time of the crime. However, the court found these claims unconvincing, highlighting the possibility of their departure to Lubao before the crime occurred.
Classification of Crime
The Supreme Court addressed the classification of the crime, asserting that the killing of Damaso Valencia and the subsequent robber
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Case Background
- The case involves the prosecution of Severino Perez, Abdon de Leon, Faustino Manago, and Lorenzo Reyes for the crime of robbery with murder.
- The complaint was filed by the fiscal of Pampanga on June 6, 1914, detailing the events of July 4, 1912, at the fishery of Damaso Valencia in Lubao, Pampanga.
- The accused were alleged to have entered the victim's residence under the pretense of buying fish, leading to a violent attack and subsequent murder of Damaso Valencia.
Indictment Details
- The accused were charged with robbery with murder, involving:- Armed assault on Damaso Valencia with bolos and a revolver.
- Infliction of 38 wounds, some fatal, resulting in immediate death.
- Theft of P327 in paper money, P48 in silver coins, and jewelry valued at P600.
- Binding Miguela Sibug, the victim's wife, to facilitate the robbery.
 
- The acts were characterized by aggravating circumstances: treachery, nocturnity, unlawful entry, and unusual cruelty.
Trial Proceedings
- The accused pleaded not guilty and underwent a trial in the Court of First Instance.
- During the trial, Lorenzo Reyes was excluded from the complaint to appear as a witness for the prosecution.
- The trial court found Perez, de Leon, and Manago guilty, attributing to them the aggravating circumstances listed in the complaint.