G.R. No. L-18523-26 April 30, 1966
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BALBAL SIGAYAN, ET AL., defendants, BALBAL SIGAYAN, defendant-appellant.

FACTS

Balbal Sigayan was charged in four separate cases before the Court of First Instance of Lanao for crimes arising from the events of January 8, 1955. In Criminal Cases Nos. 1690 and 1797, he was accused of robbery with homicide for the taking of cash and properties worth P3,050.00 from the spouses Anacleto and Laureana Madrina, during which Anacleto Madrina and his daughters Juana and Elena were killed. In Criminal Cases Nos. 1841 and 1843, he was accused of murder for the deaths of Leodegario Mendez and Laureano Alongay on the same occasion. The cases against his co-accused were dismissed, with Demasindel Timba discharged to become a state witness. After trial, the court found Sigayan guilty in all four cases. In Criminal Cases Nos. 1690 and 1797 (robbery with homicide), he was sentenced to death, with aggravating circumstances of dwelling, band, evident premeditation, and treachery. In Criminal Cases Nos. 1841 and 1843 (murder), he was sentenced to reclusion perpetua. Sigayan did not appeal, but the death penalty imposed triggered an automatic review by the Supreme Court of the robbery with homicide cases.
The prosecution evidence established that on the evening of January 8, 1955, an armed band led by Makasiro Tamiara, which included Balbal Sigayan, Demasindel Timba, and Desoma Timba, attacked two neighboring houses in Kalubihon, Dalipuga, Iligan City. They fired shots into the houses, resulting in the deaths of Anacleto Madrina, Juana Madrina, Elena Madrina, Leodegario Mendez, and Laureano Alongay, and the wounding of others. The house of Anacleto Madrina was then robbed of cash and firearms. Demasindel Timba testified that he and his cousin Desoma were coerced to accompany the band and carry loot, while Sigayan actively participated in the shooting and robbery. Sigayan was later captured carrying part of the loot. The defense version, testified solely by Sigayan, claimed he was forced under threat of death to accompany the band, was left under guard during the attack, and later surrendered voluntarily.

ISSUE

The determinative issue for the Supreme Court’s automatic review of the death penalty in the robbery with homicide cases (Crim. Cases Nos. 1690 and 1797) was the credibility of witnesses, specifically whether the prosecution sufficiently proved that Balbal Sigayan was an armed and active participant in the crimes, or whether his defense of being a coerced companion should be believed.

RULING

The Supreme Court affirmed the trial court’s decision in toto, including the imposition of the death penalty for robbery with homicide. The Court found the testimony of state witness Demasindel Timba to be clear, convincing, straightforward, and corroborated by other witnesses, including the investigating officer and the municipal judge before whom Sigayan’s written declaration was attested. The trial judge correctly gave credence to this testimony over the sole, uncorroborated testimony of Sigayan. The Court rejected the defense arguments: (1) that the deaths in the Mendez house were accidental, noting that the murder convictions were not appealed and were final; (2) that the non-presentation of Desoma Timba as a witness implied suppressed favorable testimony, as the prosecution was not obligated to present him and the State’s case was already sufficient; and (3) that the mitigating circumstance of voluntary surrender applied, as the evidence showed Sigayan surrendered only after being surrounded by authorities, which was not voluntary. The aggravating circumstances of dwelling, band, and evident premeditation, with no mitigating circumstances, justified the imposition of the death penalty.