G.R. No. L-583 : October 15, 1902
THE UNITED STATES, complainant-appellee, vs. ISIDRO PADDIT, ET AL., defendants-appellants.

FACTS:
The defendants, Isidro Paddit, Marcelino Lozano, and Julian Serios, were charged with the complex crime of robbery en cuadrilla resulting in homicide. The prosecution alleged that one night in November 1900, in San Nicolas, the defendants went to the house of Jacob de la Cruz, bound him, and took him to a location where he had hidden a package containing jewelry and other articles belonging to Gregorio Mejia. There, they committed the robbery and killed de la Cruz. The Court of First Instance found them guilty under Article 503 of the Penal Code and imposed the death penalty. The defendants appealed, presenting an alibi defense through family members, which the court did not credit.

ISSUE:
Whether the evidence presented is sufficient to convict the defendants of the complex crime of robbery with homicide.

RULING:
No. The Supreme Court reversed the judgment of the Court of First Instance. While the evidence was sufficient to establish the defendants’ guilt for the homicide of Jacob de la Cruz, the element of robbery was not proven beyond a reasonable doubt. No witness saw the defendants take the hidden package, and none of the stolen property was found in their possession. The evidence regarding the existence and location of the package at the time of the killing was circumstantial and insufficient.

Applying Section 29 of General Orders No. 58, which allows a conviction for an offense necessarily included in the charge, the Court found the defendants guilty of the lesser included offense of homicide. The aggravating circumstance of nocturnity was appreciated. Accordingly, the defendants were each sentenced to seventeen years, four months, and one day of reclusion temporal in its medium degree under Article 404 of the Penal Code, with an order to indemnify the family of the deceased in the amount of 1,000 pesos, Mexican, and to pay the costs of suit.