People v. Macamay
REITERATIONFacts
The Antecedents: On the night of May 5, 1915, an armed band of seven men robbed the house of Juan Mar in Catarman, Misamis. The robbers entered the house with threats, demanded money, and took P2,500 in bills and a few articles worth P5 from a trunk. Lorenzo Tinampay was identified as one of the principal participants. Procedural History: Six individuals were convicted in the Court of First Instance. Nicolas Macamay, the appellant, was tried with three others. He was convicted and sentenced to twelve years and one day of cadena temporal. The Petition: The defendant Nicolas Macamay appealed his conviction.
Issue(s)
Whether the evidence presented is sufficient to convict the appellant Nicolas Macamay of robbery en cuadrilla. Whether the crime committed falls under Article 508 of the Penal Code (robbery with false keys) or under Article 503 in relation to Articles 504 and 505 (robbery en cuadrilla with violence or intimidation).
Ruling
The Supreme Court affirmed the conviction of Nicolas Macamay but modified the penalty. The Court ruled that the crime committed was robbery en cuadrilla with violence or intimidation against the person, with the aggravating circumstances of nocturnity and commission in the dwelling of the injured person, and sentenced the appellant to ten years of presidio mayor, with accessory penalties.
Ratio Decidendi
On the sufficiency of evidence to convict Nicolas Macamay: The Court found the testimony of co-accused Nicolas Ranollo and Benigno Madria, who admitted their participation in the crime, to be credible and reasonable. Their testimony was substantially corroborated by the testimony of Francisco Bacleon, another co-accused who also admitted guilt and testified against Macamay. The Court noted that Macamay's presence at his house just before the robbery, where the band was entertained, was an important circumstance against him. Macamay's attempt to prove an alibi was found unconvincing. The Court emphasized that the testimony of these witnesses, who were likely seeking leniency, was given with the hope of a true statement of the transaction, and that it was natural for them to place the chief blame on the principal authors of the crime. The Court concluded that Macamay's complicity was shown with the certainty required by law. On the classification of the crime and applicable penalty: The Court held that the trial court erred in applying Article 508 of the Penal Code, which pertains to robbery with the use of false keys. The Court clarified that the use of false keys in Article 508 refers to the mode of entering the house, not the method of opening a trunk within the house. In this case, the robbers entered through the door. Therefore, Article 508 was inapplicable. The Court determined that the crime committed was robbery en cuadrilla, with violence or intimidation against the person, and aggravated by nocturnity and the commission of the crime in the dwelling of the injured person. This crime should be punished under subsection 5 of Article 503, in relation to Articles 504 and 505 of the Penal Code. Consequently, the penalty imposed by the trial court was modified from twelve years and one day of cadena temporal to ten years of presidio mayor, with accessory penalties.
Main Doctrine
The testimony of co-accused, even if admitting their own guilt, can be credible and sufficient to convict another accused, especially when corroborated by other evidence or circumstances, and when the accused fails to convincingly prove an alibi. The crime of robbery en cuadrilla with violence or intimidation against persons, with the aggravating circumstances of nocturnity and commission in the dwelling of the injured person, is punished under specific provisions of the Penal Code, not under those pertaining to the use of false keys for opening a trunk.