GR L 4158; (March, 1908) (Digest)
G.R. No. L-4158
THE UNITED STATES, plaintiff, vs. MATEO CARIÑO, ET AL., defendants.
March 20, 1908
FACTS:
About midnight on April 24, 1907, Mateo Cariño, Gabriel Valenzuela, Daniel de Guzman, Jose Valenzuela, Isidro Valenzuela, and Narciso Centeno, armed with bolos, forced their way into the house of Francisco Darapisa in Manaoag, Pangasinan. Darapisa resisted their command to lie down, wounded one of the attackers (later identified as Mateo Cariño), and fled, pursued by the band. His wife escaped to a neighbor’s house. The robbers then rifled a trunk, taking P7. When Darapisa’s wife returned, she found his dead body in a canebrake nearby, with fourteen bolo wounds, half of which were fatal.
The crime was identified as robo con homicidio (robbery with homicide), aggravated by being committed by an “armed band” at night and in the victim’s dwelling. The trial court imposed the death sentence on the defendants, except for Narciso Centeno, who received cadena perpetua (life imprisonment) and did not appeal. The other defendants appealed, challenging the sufficiency of the prosecution’s evidence regarding their identity.
The prosecution’s evidence included:
1. The victim’s widow positively identified all defendants by lamp light, even testing her memory by correctly identifying a substituted prisoner.
2. Narciso Centeno confessed his guilt and named other participants (admitted only against Centeno).
3. Witnesses saw Isidro Valenzuela and Daniel de Guzman carrying something in a hammock at daybreak, and later saw them carrying a wounded Mateo Cariño into Gabriel Valenzuela’s house.
4. Mateo Cariño was found in Gabriel Valenzuela’s house, concealed in a blanket, with a fresh bolo wound he tried to hide and falsely explain.
5. The deceased’s bolo was found near Gabriel Valenzuela’s house, and three blood-smeared bolos and a spear were found concealed in Jose Valenzuela’s backyard.
6. The defense’s alibi was found unconvincing.
ISSUE:
Whether the prosecution sufficiently proved the identity of the defendants as the perpetrators of the robo con homicidio beyond a reasonable doubt.
RULING:
Yes. The Supreme Court affirmed the trial court’s findings, holding that the evidence of record sufficiently established the identity and guilt of the accused beyond a reasonable doubt. The positive identification by the victim’s widow, coupled with corroborating circumstantial evidence including the discovery of Mateo Cariño’s fresh wound (matching the wound inflicted by Darapisa), the sighting of other defendants carrying Cariño, and the finding of Darapisa’s bolo and blood-stained bolos belonging to the accused near their homes convincingly linked the defendants to the crime. The defense’s alibi was dismissed as unconvincing. Therefore, the judgment of conviction and the sentences imposed by the trial court, including the death sentence for the appealing defendants and cadena perpetua for Narciso Centeno, were affirmed.
