Nighttime NOT always aggravating

By and of itself, nighttime is not an aggravating circumstance, however, it becomes aggravating only when: (1) it is especially sought by the offender; or (2) it is taken advantage of by him; or (3) it facilitates the commission of the crime by ensuring the offender’s immunity from capture. (People vs. Arrojado, G.R. No. 130492, 31 January 2001, 350 SCRA 679)