The Supreme Court affirmed the conviction of Dante Piandiong, Jesus Morallos, and Archie Bulan for robbery with homicide, emphasizing that when a homicide occurs during a robbery, all participants are principals regardless of direct involvement in the killing, unless they actively tried to prevent it. This ruling clarifies that participation in the initial conspiracy to commit robbery extends to the resulting homicide, highlighting the shared responsibility of accomplices in violent crimes.

When a Hold-Up Turns Deadly: How Far Does Criminal Liability Extend?

The case arose from an incident on February 21, 1994, when Percival Catindig, PO1 Gerry Perez, Leonisa S. Bacay, and Rowena Reyboneria boarded a jeepney in Kalookan City. Shortly after, a group including Piandiong, Morallos, and Bulan, announced a hold-up, robbed the passengers, and fatally shot PO1 Perez. The accused were charged with robbery with homicide, and the trial court found them guilty, sentencing them to death. The case then reached the Supreme Court on automatic review due to the imposed death penalty.

Accused-appellant Bulan argued that the prosecution failed to establish conspiracy with positive evidence, asserting that merely holding a gun during the robbery did not demonstrate a shared criminal intent in the homicide. The Supreme Court, however, rejected this argument, underscoring that the collective actions of the accused clearly indicated a conspiracy. The Court highlighted that Bulan and his co-accused boarded the jeepney together, brandished their firearms, announced the robbery, and divested passengers of their valuables. These actions, considered jointly, demonstrated a concerted effort towards a common criminal objective. The Supreme Court cited People vs. Amaguin, 229 SCRA 166 [1994], emphasizing that “[t]here is no need to prove a previous agreement among the felons to commit the crime if by their overt acts it is clear that they acted in concert in the pursuit of their unlawful design.” This principle reinforces that conspiracy can be inferred from the conduct of the accused during the commission of the crime.

Piandiong and Morallos contested their identification, suggesting that police influence led the witnesses to falsely identify them. The Court dismissed this claim, highlighting that there was no evidence of ill motive on the part of the witnesses, and their testimonies were consistent and credible. In fact, it emphasized the absence of any evidence indicating that the prosecution witnesses were driven by improper motives that would cause them to falsely accuse the accused-appellants. Given this absence, the presumption stands that their testimony is truthful and deserving of full faith and credit. The Court also pointed out that the close proximity between the witnesses and the robbers during the incident facilitated clear identification. Additionally, the Court referenced People vs. De la Cruz, 229 SCRA 754 [1994] and People vs. Perciano, 233 SCRA 393 [1994], which states that “[w]hen there is no showing that the prosecution witnesses were actuated by any improper motive, the presumption is that they are not so actuated and their testimony is entitled to full faith and credit.”

Addressing concerns about the police line-up, the Court noted that any irregularity in the procedure did not invalidate the positive identification made by the witnesses in court. The Court also cited People vs. Sartagoda, 221 SCRA 251 [1993] and People vs. Buntan, Sr., 221 SCRA 421 [1993], stating that “[a] police line-up is not essential,” and that judicial decisions are based on testimony and other evidence presented in court, not on extraneous matters occurring during the police investigation.

All three accused-appellants presented alibis, claiming to be elsewhere during the crime. The Court deemed these alibis insufficient, as the locations provided were within relatively short distances from the crime scene, making it physically possible for them to be present during the robbery and homicide. Moreover, the Court stressed that alibis cannot outweigh positive eyewitness identification, especially when the witnesses have no apparent reason to lie. Citing People vs. Javier, 229 SCRA 638 [1994] and People vs. Talaver, 230 SCRA 281 [1994], the Court reiterated that accused-appellants’ alibis cannot prevail over their positive identification by eyewitnesses who had no improper motive to falsely testify.

Regarding the argument that the trial court should have summoned additional witnesses, the Supreme Court noted that the defense had the opportunity to request subpoenas for these witnesses but failed to do so. Therefore, the responsibility for not presenting these witnesses rested with the accused-appellants themselves.

The Court then turned to the elements of robbery with homicide, noting that the death of PO1 Gerry Perez during the robbery was undisputed. It emphasized that under Philippine law, as stated in People vs. Saliling, 69 SCRA 427 [1976], “it is enough that a homicide results by reason or on the occasion of robbery.” All those who participate in the robbery are held responsible as principals for the crime of robbery with homicide, regardless of their direct involvement in the killing, unless they actively tried to prevent it, as cited in People vs. Balanag, 236 SCRA 474 [1994]. As Bulan and Morallos made no effort to stop Piandiong from shooting PO1 Perez, their liability was deemed equal.

The Supreme Court agreed with the trial court’s imposition of the death penalty, citing the aggravating circumstance of band, as the crime involved more than three armed malefactors acting in concert. With one aggravating circumstance and no mitigating circumstances, the maximum penalty was deemed appropriate. The court cited People vs. Dela Cruz, supra, highlighting the importance of the number of malefactors involved.

In summary, the Supreme Court upheld the conviction, underscoring the principle that participation in a robbery resulting in homicide leads to a shared responsibility for the resulting crime, and the defense of alibi is weak against positive eyewitness identification. The Court emphasized that when homicide takes place as a consequence or on the occasion of a robbery, all those who took part in the robbery are guilty as principals of the crime of robbery with homicide, even if they did not actually participate in the killing. The only exception is when it is clearly shown that they endeavored to prevent the unlawful killing.

FAQs

What is robbery with homicide under Philippine law?	Robbery with homicide is a crime where a person commits robbery, and on the occasion or by reason of the robbery, a homicide (killing) occurs. The crime is a single, indivisible offense punishable under Article 294 of the Revised Penal Code.
What does conspiracy mean in the context of robbery with homicide?	Conspiracy means that two or more people agreed to commit a crime, and as a result of that agreement, the crime was committed. If one person kills someone during the commission of the planned robbery, all parties to the conspiracy are equally responsible for the homicide, even if they did not directly participate in the killing.
What is the significance of “band” in this case?	“Band” refers to the presence of more than three armed malefactors acting together in the commission of a crime. Under Article 14 of the Revised Penal Code, committing a crime through a band of armed individuals is considered an aggravating circumstance, which can influence the severity of the penalty imposed by the court.
How does the court determine the credibility of witnesses?	The court assesses the credibility of witnesses by considering factors such as their demeanor, consistency of testimony, and the presence or absence of any motive to lie. If there is no clear evidence of ill motive, the court generally presumes that the witnesses are telling the truth and gives their testimony full weight.
Why was the defense of alibi rejected in this case?	The defense of alibi was rejected because the accused could not prove that it was physically impossible for them to be present at the crime scene at the time the crime was committed. Additionally, positive identification by eyewitnesses outweighed the accused’s claims of being elsewhere.
What is the effect of an aggravating circumstance in sentencing?	An aggravating circumstance, such as the commission of the crime through a band, increases the severity of the penalty that can be imposed by the court. In the absence of any mitigating circumstances, the presence of an aggravating circumstance may lead to the imposition of the maximum penalty provided by law for the offense.
What happens when the penalty is death in the Philippines?	Although the death penalty was imposed in this case, it’s important to note that the death penalty was later suspended in the Philippines. Even when it was in effect, cases involving the death penalty were automatically reviewed by the Supreme Court, and upon finality of the decision, the records were forwarded to the Office of the President for possible exercise of the pardoning power.
Can someone be guilty of robbery with homicide even if they didn’t directly kill the victim?	Yes, under Philippine law, if a homicide (killing) occurs during the commission of a robbery, all those who participated in the robbery can be found guilty of robbery with homicide, even if they did not directly participate in the killing. The only exception is if they made genuine efforts to prevent the killing.

This case underscores the importance of understanding the legal implications of participating in criminal activities. The principle that all conspirators are equally liable for the consequences of their actions, including unintended outcomes like homicide, serves as a strong deterrent. It reinforces that even indirect involvement in a crime can lead to severe penalties, emphasizing the need for individuals to carefully consider the potential ramifications of their choices.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People v. Piandiong, G.R. No. 118140, February 19, 1997