GR 1714; (April, 1905) (Digest)
G.R. No. 1714
Date: April 14, 1905
Parties:
– Complainant-Appellee: The United States
– Defendants-Appellants: Esteban Logario, et al.
FACTS:
The defendants were charged with the crime of bandolerismo under Act No. 518 . The information alleged that on or about December 12, 1902, and up to April 1903, in the Province of Rizal, the defendants conspired with known leaders such as Luciano San Miguel, Ciriaco Contreras, Faustino Guillermo, and Apolonio Sampson, and others unknown, to form an armed band of robbers. The band was armed with guns, revolvers, and other deadly weapons, and its purpose was to steal carabaos and other personal property through force and violence. The band operated on highways and roamed the countryside. The defendants were within the police jurisdiction of Manila during much of the conspiracy period and were eventually captured within the city, placing them under the jurisdiction of the Court of First Instance of Manila. After trial, the court found each defendant guilty and imposed the death penalty. The case was elevated to the Supreme Court en consulta (automatic review due to the death penalty). By agreement of the prosecution and defense, the evidence presented in a related case, United States v. Calixto Aquino et al., was also applied to this case.
ISSUE:
Whether the penalty of death imposed by the trial court was appropriate, considering the degree of participation of the defendants in the crime of bandolerismo.
RULING:
The Supreme Court affirmed the conviction for bandolerismo but modified the penalty. The Court found the evidence sufficient to prove the defendants’ guilt beyond reasonable doubt as members of the armed band. However, the evidence did not establish that they were organizers, chiefs, or leaders of the band. Their level of participation was comparable to that of the defendants in G.R. No. 1713 (United States v. Potenciano Comia and Urbano Villanueva), who were sentenced to twenty-five years of imprisonment. Therefore, the death penalty was deemed excessive and not warranted by their degree of culpability. The Supreme Court reversed the trial court’s sentence and instead sentenced each defendant to twenty-five years of imprisonment, with an order to pay one-third of the costs.
Arellano, C.J., Torres, Mapa, and Carson, JJ., concurred.