G.R. No. 1141 : April 4, 1903
THE UNITED STATES, complainant-appellee, vs. ELENO LIUANAG, ET AL., defendants-appellants.

FACTS:
The defendants-appellants, Eleno Liuanag, Quinto, Sinambal, and Joaquin, were convicted by the Court of First Instance of Rizal for the crime of robo en cuadrilla (robbery in band) under the Penal Code. They were sentenced to six years, ten months, and one day of presidio mayor. The evidence established that Constabulary officers captured Quinto, Sinambal, and Joaquin in a banca on the Atlag River in Malolos, Bulacan, in September 1902. Found in their possession were stolen items, including two sewing machines and money. Their apprehension led to the arrest of Liuanag, in whose possession stolen jewelry, money, a gun, and cartridges were found. The appellants confessed to their involvement in robberies. The stolen sewing machines and jewelry were identified in court by their owners, Candida Garcia and others, who testified that the items were taken from their houses in the barrio of Dampalit, Malabon, Rizal, by an armed band of robbers at night. The defense presented no witnesses.

ISSUE:
Whether the conviction for robo en cuadrilla was proper and whether the penalty imposed by the trial court was correct in light of aggravating circumstances.

RULING:
The Supreme Court affirmed the conviction for robo en cuadrilla. The evidence conclusively proved that the appellants belonged to an armed band of outlaws that committed robberies in Dampalit. However, the Court modified the penalty. The trial court erred in not appreciating the aggravating circumstances of nocturnity (nighttime) and band (acting in a band of more than three armed malefactors) under Article 10 of the Penal Code. Consequently, the penalty should be imposed in its maximum degree. The Supreme Court increased the penalty to ten years of presidio mayor. The judgment was modified accordingly and affirmed in all other respects.