GR 1943; (April, 1905) (Digest)
G.R. No. 1943 : April 17, 1905
THE UNITED STATES, complainant-appellee, vs. BENITO SANTA ANA, defendant-appellant.
FACTS:
Benito Santa Ana was charged with the crime of bandolerismo under Act No. 518. The complaint alleged that after November 12, 1902, in Bulacan, he, together with Luciano San Miguel, Ciriaco Contreras, Apolonio Samson, and others, formed an armed band of more than three persons that roamed the country to steal carabaos and other property by means of force and violence. After a separate trial was granted, the Court of First Instance convicted him and sentenced him to twenty-five years of imprisonment. The defendant appealed.
The evidence established that Benito Santa Ana, after having previously taken an oath of allegiance to the U.S. Government, later rejoined insurgent forces and became a subchief within the band of Luciano San Miguel. This band, armed with rifles and other deadly weapons, operated in divisions. Santa Ana’s division, along with others, engaged in a series of criminal acts including: invading towns (Cainta, Antipolo, Pasig, etc.); robbing private homes and Constabulary quarters; stealing rice, goods, and provisions from travelers and townspeople; and capturing individuals (such as Pedro de la Cruz and Mariano de la Cruz) to demand ransom or supplies. Although the band initially had political aims, its activities after November 12, 1902, were characterized by systematic robbery and pillage.
ISSUE:
Whether the defendant, Benito Santa Ana, is guilty of the crime of bandolerismo as defined and punished under Act No. 518.
RULING:
Yes, the Supreme Court affirmed the judgment of conviction. The Court held that the evidence fully proved that the band led by Luciano San Miguel, of which Santa Ana was a subchief, constituted a band of brigands. Despite any original political character, the band’s activities after the specified dateincluding robbery, pillage, invasion of towns, and kidnapping for ransomfell squarely within the definition of bandolerismo under Act No. 518. The defendant’s active participation as a commander of one of its divisions was established by the prosecution’s evidence, which overcame his plea of not guilty. Therefore, the penalty of twenty-five years’ imprisonment imposed by the lower court was proper. The Supreme Court affirmed the sentence with costs de oficio.