CASE DIGEST

PEOPLE v. MANGULABNAN
Law 110 Criminal Law II – Robbery with Homicide

Court Supreme Court

Citation G.R. No. L-8919
Date 28 September 1956
Plaintiff-Appellee People of the Philippines
Defendant-Appellant Agustin Mangulabnan a.k.a. Guinita, et. al.
Ponente Felix
Relevant Topic Robbery with Homicide
Prepared by Lawdemhar Cabatos

FACTS:

 5 November 1953 – Spouses Vicente Pacson and Cipriana Tadeo and their four minor children were awaken
by reports of gunfire in their house. Vicente Pacson shouted to one Tata that persons were going up their
house and then hid himself inside the ceiling. Thereafter, multiple people, including Agustin Mangulabnan,
who was positively identified by Cipriana, forcibly entered their house by breaking the wall of the kitchen.
 Mangulabnan approached Cipriana Tadeo and snatched from her neck one necklace valued at P50 and also
took P50 in paper bills, and P20 in silver coins.
 Cirpriana’s mother, Monica del Mundo, was searched by one of the intruders and took from her P200 in cash
and a gold necklace valued at P200. The intruder also demanded that she give him her diamond ring.
 One of the unidentified individuals climbed on the table and fired his gun at the ceiling. Afterwards, appellant
and his two unidentified companions left.
 Vicente Pacson was found dead in the ceiling lying face downward due to severe hemorrhage caused by a
gunshot wound of the frontal region of the forehead.
 Appellant Mangulabnan admitted his participation in the robbery and killing of Vicente Pacson and was
eventually found guilty of the crime of robbery with homicide and sentenced to reclusion perpetua.
 Mangulabnan moved for a new trial on the ground of newly discovered evidence, but the motion was denied
for lack of merit, hence, this appeal.

ISSUE– HELD – RATIO:

ISSUE (Relevant to the topic) HELD

WoN the appellant is guilty of robbery with homicide. YES

The motion for a new trial was based on the affidavits of Dr. Numeriano D. Lustre, Marino Ventura,
Marcosa Mudlong and Patricio Gonzales but they were not really newly discovered nor could they alter
the conclusion arrived at by the trial Court.

(The case did not specify the details of the affidavits.)

General Rule: Before a new trial may be granted on the ground of newly discovered evidence, it must
be shown:

(a) That the evidence was discovered after trial;

(b) That such evidence could not have been discovered and produced at the trial even with the
exercise of reasonable diligence; and
(c) That it is material, not merely cumulative, corroborative or impeaching, and of such a weight that
it would probably change the judgment if admitted.

The motion for new trial did not comply with these requisites and was properly denied by the trial Court.

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CASE DIGEST
PEOPLE v. MANGULABNAN
Law 110 Criminal Law II – Robbery with Homicide

There is no denial that the crime of robbery with homicide was committed as described in the
information.

By appellant's own admission and the testimony of Cipriana Tadeo, there is no doubt as to appellant's
participation in the execution thereof. Appellant and the rest of the malefactors came together to the
house of the offended parties to commit the robbery perpetuated therein and together went away from
the scene of the crime after its perpetration. This shows conspiracy among the offenders which
rendered each of them liable for the acts of the others.

The record shows that appellant participated in the criminal design to commit the robbery with his
codefendants and it is a settled rule in this jurisdiction that unity of purpose and action arising from a
common design makes all parties thereto jointly liable, each being responsible for the result,
irrespective of the character of their individual participation.

In order to determine the existence of the crime of robbery with homicide under Article 294 (1), it is
enough that a homicide would result by reason or on the occasion of the robbery. It is immaterial that
the death would supervene by mere accident, provided that the homicide be produced by reason or on
occasion of the robbery, inasmuch as it is only the result obtained, without reference or distinction as
to the circumstances, causes, modes or persons intervening in the commission of the crime, that has
to be taken into consideration.

The commission of the offense was attended by the aggravating circumstances of nighttime, dwelling,
abuse of superior strength and with the aid of armed men, meriting the sentence of capital punishment.
However, for lack of votes required to impose capital punishment, the penalty to be imposed is the next
lower in degree or reclusion perpetua.

RULING:

WHEREFORE, the decision appealed from, being in accordance with law and the evidence, is hereby
AFFIRMED with costs against appellant.

SO ORDERED.

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