People v. Quijano
REITERATIONFacts
The Antecedents: After 10 o'clock at night on January 17, 1907, six armed individuals assaulted the house of Manuel Boydon and Josefa Flores. While some entered, others remained in the yard. The assailants, through intimidation and threats of death, stole P9.40. Upon leaving, they dragged Josefa Flores a distance and demanded P10 more, but she did not return as she met her husband and residents who were searching for her. The robbers fired two shots during the commission of the crime. Procedural History: The provincial fiscal filed a complaint for robbery en cuadrilla against six individuals and others unknown. The trial court convicted five accused, sentencing them to ten years of presidio mayor, jointly and severally pay an indemnity of P9.40, and costs. The accused appealed. The Petition: The accused appealed the judgment of the trial court.
Issue(s)
Whether the facts proven constitute the crime of robbery en cuadrilla. Whether Alejandro Quijano, Cipriano Candelaria, and Sotero Quitalig are guilty as principals by direct participation in the robbery en cuadrilla. Whether Mamerto Garcia and Agustin Macaspac are guilty of the crime. Whether the aggravating circumstances of nighttime and dwelling, and the recidivism of Candelaria, should be considered. Whether the motion for a new trial presented by counsel for Sotero Quitalig should be admitted.
Ruling
The Court affirmed the conviction of Alejandro Quijano, Cipriano Candelaria, and Sotero Quitalig, sentencing each to ten years of presidio mayor, with accessory penalties, jointly and severally to indemnify the injured parties in the sum of P9.40, without subsidiary imprisonment, and to pay one-fifth of the costs. Mamerto Garcia and Agustin Macaspac were acquitted, and the remaining two-fifths of the costs were declared de officio. The motion for a new trial was denied.
Ratio Decidendi
On whether the facts proven constitute the crime of robbery en cuadrilla: The Court held that the proven facts, including the robbery of P9.40 by means of intimidation and threats, carried out by six armed individuals accompanied by others in the yard, and the firing of two shots to intimidate the victims and inhabitants, fully constitute the crime of robbery en cuadrilla as defined and punished by articles 502 and 503, No. 5, in connection with article 504 of the Penal Code. The testimony of the aggrieved parties and neighbors corroborated these facts. On the guilt of Alejandro Quijano, Cipriano Candelaria, and Sotero Quitalig: The Court found sufficient evidence to convict these three defendants as proven principals by direct participation. Despite their denial and attempts to prove an alibi, the injured woman, Josefa Flores, recognized them when she was seized and maltreated. Although she initially feared to name them due to threats, she later identified them through her son. Her husband, Manuel Boydon, confirmed her statement, recognizing Quijano and the voices of Candelaria and Quitalig, who directed the actions of those inside the house. The barrio lieutenant also corroborated the injured woman's statement, leading to the arrest of the accused who were residents of the same barrio. On the guilt of Mamerto Garcia and Agustin Macaspac: The Court acquitted Garcia and Macaspac, finding that the injured woman's identification of them was an isolated statement not corroborated by any other evidence tending to prove their culpability. The Court emphasized that in the absence of satisfactory evidence, the presumption of innocence must be given greater weight, and it is not incompatible with strict justice to give them the benefit of reasonable doubt. On the aggravating circumstances and recidivism: The Court considered the aggravating circumstances of having committed the crime at night and in the dwelling of the aggrieved parties. It also noted that Candelaria is a recidivist, having previously served a term for theft, and Quitalig had been prosecuted for robbery. These circumstances warranted the imposition of the penalty in the maximum degree. On the motion for a new trial: The Court denied the motion for a new trial presented by counsel for Sotero Quitalig, finding that it did not comply with the provisions of section 42 of General Orders, No. 58, and the requisites set forth in the case of U.S. vs. Luzon. Furthermore, the Court reasoned that the affirmative declarations of the witnesses cited in the motion would not have altered the outcome of the proceedings or affected the judgment appealed from.
Main Doctrine
Robbery en cuadrilla is committed when a robbery is perpetrated by six or more armed individuals, with the presence of aggravating circumstances such as nighttime and commission in the dwelling of the offended parties, and the commission of the crime by a recidivist.