GR L 3973; (November, 1907) (Digest)
G.R. No. L‑3973
November 26, 1907
FACTS
On the night of 28 June 1906 a band of eight armed men entered the house of Macario Castañeda (who was absent) in Batuan, Negros Occidental. Five entered the dwelling, brandishing bolos and daggers, and forced the occupants to reveal and surrender cash (₱420) and clothing (₱20). The assailants also seized the women and laborers present, sequestered them for about thirty minutes, and threatened them with death to silence any report. The victims identified three of the intrudersMartin Sol, Sotero Guardiano, and Ciriaco Amparo. Witnesses, including laborer Marcelo Sembrano and elder Vicente Villan, corroborated the identification and testified that the three accused later divided the stolen proceeds. The prosecution charged robbery “en cuadrilla” under Articles 502, 503(5) in relation to Articles 504‑505 of the Penal Code. The trial court sentenced each of the three accused to six years 10 months 1 day of presidio mayor, ordered joint restitution of ₱420, and suspended proceedings against the absent participants. On appeal, the same sentence was reaffirmed, and the defendants sought reversal on grounds of insufficient identification and alleged illegal detention.
ISSUE
Whether the conviction and penalty imposed on Martin Sol, Sotero Guardiano, and Ciriaco Amparo for robbery in a band (cuadrilla) are upheld, and whether the act of briefly restraining the victims constitutes the crime of illegal detention.
RULING
The Supreme Court held that the evidencevictim identification, corroborating eyewitness testimonies, and the defendants’ own admissionsproved the guilt of the three accused beyond reasonable doubt. The brief sequestration of the victims was deemed a customary means of a robber to prevent immediate reporting, not the independent offense of illegal detention; thus, no separate liability for illegal detention was imposed. Applying the qualifying circumstance of “cuadrilla” and the aggravating circumstance of nighttime robbery in a dwelling, the Court increased the penalty to the maximum authorized: ten (10) years of presidio mayor, accessory penalties under Article 57, restitution of the stolen clothing (₱20) or payment thereof, restitution of the cash (₱420), and each accused to bear one‑third of the costs of both instances. The original judgment was modified accordingly and affirmed.