**Facts:**
On the night of July 2, 1966, in Sitio Suapit, Barrio Limot, Mati, Davao, a horrifying series of crimes unfolded involving robbery in band, arson, and robbery with homicide and physical injuries. The accused included Abraham Lim alias Titing Lim, Ceferino Caturan alias Fred, Romualdo Raboy alias Romy, Saturnino Galliano, and several others, who were charged separately in three criminal cases (Nos. 9987-9989) before the Court of First Instance of Davao. The sequence of events began with the armed men, allegedly identified as Raboy and Señeres, robbing Gorgonio Mosende’s house and proceeded to the house of George Kalitas, a notable figure in the community. There, they committed a robbery with homicide and arson, culminating in the death of George Kalitas, physical injuries to others, and extensive property damage.
Following the incidents, an extensive investigation led by the 433rd PC Company and Davao City Police Department eventually resulted in the apprehension of the accused individuals alongside the recovery of various pieces of evidential weaponry and the vehicle implicated in the atrocities, leading to their subsequent trial.
**Issues:**
1. Whether the accused were the perpetrators of the offenses charged.
2. The appropriate classification and separate individuality of each offense committed.
3. The evaluation and applicability of the aggravating circumstances mentioned, including nighttime, use of a motor vehicle, and use of unlicensed firearms.
4. The determination of the penalty imposed, considering the aggravating circumstances.
5. Whether the absence of Abraham Lim during the trial constitutes an infringement of his right to be present at every stage of the proceedings.
**Court’s Decision:**
The Supreme Court affirmed the trial court’s decision with modifications. It was concluded based on the collective and corroborative testimonies of the witnesses that the accused were indeed the perpetrators. The acts committed were constituted as separate offenses due to their distinct nature and the different acts involved. The aggravating circumstances of nighttime, the use of a motor vehicle, and use of unlicensed firearms were considered appropriately, although the use of unlicensed firearms was not considered an aggravating circumstance in the arson and robbery with homicide cases due to its specific applicability to robbery in band under the Revised Penal Code. The penalty was adjusted accordingly, with Abraham Lim, Ceferino Caturan, Romualdo Raboy, and Saturnino Galliano receiving indeterminate sentences reflective of the gravity and the circumstances of their crimes including adjustments to the amounts for indemnification for the heirs of the deceased.
**Doctrine:**
This case affirmed doctrines relating to the distinct individuality of crimes despite occurring in a continuous sequence, the applicability of specific aggravating circumstances to certain crimes, and the principles surrounding the absence of an accused in trial sessions for non-capital offenses.
**Class Notes:**
– The distinction between separate offenses committed in a continuous sequence is determined by the distinct nature and acts involved in each crime.
– Specific aggravating circumstances (e.g., use of unlicensed firearms) have limited applicability depending on the nature of the offense as defined by the Revised Penal Code.
– An accused’s absence does not infringe upon their right to be present at every stage of the proceedings if they are absent during the trial of another, or if their absence is unjustified during their own trial proceedings.
**Historical Background:**
The crimes occurred during a period in the Philippines when societal and order issues were prominent concerns. The handling and resolution of this case by the judicial system demonstrated the extent and limits of law enforcement and judicial proceedings during such times. The case also underscores the procedural and substantive nuances in Philippine criminal justice, illustrating how multiple crimes, when committed in succession, are dissected and addressed individually concerning legal requirements and evidentiary standards.
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