People v. Bautista
REITERATIONFacts
The Antecedents: Leocadio Bautista, Armando Gonzales, and Fortunato Angeles were charged with robbery with homicide in two separate informations. The prosecution alleged that while a delivery truck was cruising, an unidentified person and appellant Angeles boarded its running boards. Angeles demanded liquor money from the driver, Filemon King, who refused. The unidentified person threw a stone at the truck helper, Jose Tan, causing the truck to stop. King and Tan alighted and were met with a volley of stones thrown by Angeles, Gonzales, Bautista, and others. King asked Tan to call a policeman. Tan returned to find King sprawled on the gutter and brought him to the hospital, where he died the following morning. An autopsy revealed the cause of death to be shock and hemorrhage due to traumatic fracture of the skull and subdural hemorrhage. Procedural History: After a joint trial, the Court of First Instance of Manila found Bautista, Gonzales, and Angeles guilty beyond reasonable doubt of attempted robbery with homicide, sentencing each to reclusion perpetua, with the aggravating circumstance of superior strength, and to indemnify the heirs of the deceased. Gonzales and Angeles appealed. The Petition: Appellants Armando Gonzales and Fortunato Angeles submitted separate briefs, raising factual issues regarding their participation in the crime, the demand for liquor money, the cause of the stoning, their concerted action, and the conviction for attempted robbery with homicide. Angeles also questioned the penalty imposed and the non-consideration of mitigating circumstances.
Issue(s)
Whether the appellants acted in conspiracy, thereby making the act of one the act of all. Whether the crime was correctly classified as Attempted Robbery with Homicide under Article 297 of the Revised Penal Code. Whether the mitigating circumstance of lack of intention to commit so grave a wrong (Article 13, paragraph 3, RPC) should be considered.
Ruling
The appealed decision, modified as to the indemnity, is affirmed. The appellants are guilty of attempted robbery with homicide. The indemnity for the death of the victim is increased to P12,000.00.
Ratio Decidendi
On Issue 1: The Court held that conspiracy was established beyond reasonable doubt through the concerted action of the appellants and their companions. Although the appellants claimed separate and minor roles, the evidence showed they acted in unison to stop the truck and assault the victims after the demand for money was refused. Under the doctrine of conspiracy, the precise degree of participation of each individual is secondary to the fact that they all contributed to the common criminal purpose. The Court noted that the simultaneous boarding of the truck and the collective stoning were clear indicators of a shared intent to extort money. Consequently, the acts of those who threw the fatal stones are legally attributed to Gonzales and Angeles. Following the rule in People vs. Timbol, where conspiracy exists, all participants are deemed guilty of the attempted robbery even if only one member explicitly vocalized the demand for money. On Issue 2: The Court affirmed the classification of the crime as Attempted Robbery with Homicide under Article 297 of the Revised Penal Code. The sequence of events—the demand for 'liquor money,' the forced stopping of the truck, and the immediate assault upon the refusal—demonstrated that the killing occurred 'by reason or on occasion' of an attempted robbery. Even though the offenders failed to take any property, the commencement of the robbery through intimidation and the subsequent homicide created the complex crime defined by law. The Court emphasized that the robbery attempt was the catalyst for the violence that resulted in the driver's death. This unified criminal transaction falls squarely under Article 297, which penalizes the killing of a person during an unsuccessful robbery attempt. The presence of conspiracy further solidified the liability of all appellants for the resulting death. On Issue 3: The Court rejected the recommendation to apply the mitigating circumstance of lack of intention to commit so grave a wrong under Article 13, paragraph 3 of the Revised Penal Code. The Court reasoned that the use of stones of such 'size and weight' as to cause a commuted fracture of the skull is inherently indicative of an intent to cause serious harm or death. It is an established rule that one is presumed to intend the natural and logical consequences of their overt acts. When a group stones a victim's head with heavy objects, they cannot later claim they did not intend the resulting fatality. Furthermore, because they acted in conspiracy, the lethal intent of any member of the group is imputed to all other members. Therefore, the Court found the trial court was correct in not considering this mitigating factor in favor of the appellants.
Main Doctrine
All participants in a conspiracy to commit robbery are liable for the consequences thereof, including homicide, even if the fatal blow was not inflicted by them, as their concerted action demonstrates a common intent and they are answerable for the direct and natural consequences of their acts and those of their companions. The aggravating circumstance of superior strength may be considered even if not alleged in the information.