People v. Lago
REITERATIONFacts
The Antecedents: The Information charged appellant Reyderick Lago and four others with robbery with homicide. The prosecution alleged that on July 24, 1991, in Mandaluyong, Metro Manila, the accused, armed and conspiring, forcibly entered the house of Benjamin Raymundo by removing a window jalousie. Once inside, they stole cash and jewelry worth P92,000.00. On the occasion of the robbery, to enable them to carry out their criminal act, they stabbed Benjamin Raymundo, causing his death. Procedural History: The Regional Trial Court (RTC) of Pasig, Metro Manila, Branch 159, found appellant Reyderick Lago guilty beyond reasonable doubt of robbery with homicide, sentencing him to suffer reclusion perpetua, to indemnify the heirs of the victim P50,000.00, P18,600.00 for funeral expenses, and P67,000.00 for stolen cash and articles. The RTC ordered his commitment to the Bureau of Prisons. The Petition: Appellant Reyderick Lago appealed the RTC decision, arguing that the prosecution failed to prove his guilt beyond reasonable doubt for the crime of robbery with homicide.
Issue(s)
Whether the evidence presented by the prosecution was sufficient to convict the accused-appellant of the crime of robbery with homicide beyond reasonable doubt. Whether the accused-appellant, as a co-conspirator, is equally liable for the special complex crime of robbery with homicide, considering the elements of the crime and his actions during and after the robbery.
Ruling
The appeal is without merit. The Supreme Court affirmed the decision of the RTC, holding the appellant guilty beyond reasonable doubt of the crime of robbery with homicide.
Ratio Decidendi
On the sufficiency of evidence and co-conspirator liability: The Court reiterated that conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. Proof of conspiracy need not be direct and may be inferred from the parties' conduct indicating a common understanding and a joint or common purpose. The appellant met with his co-accused to plan the robbery, and although he claimed he only agreed to rob and not to kill, his participation in entering the victim's house and waiting while the robbery and killing occurred established his conspiracy. The Court emphasized that when conspiracy is proven, the act of one is the act of all. Therefore, the appellant is liable for the special complex crime of robbery with homicide. On the accused-appellant's liability as a co-conspirator: The Court found that all the elements of robbery with homicide were present. These include the taking of personal property with violence or intimidation against a person, the property belonging to another, the taking done with animo lucrandi, and by reason of the robbery or on occasion thereof, homicide is committed. The records showed that the appellant and his cohorts broke into the victim's house, stole valuables, and killed the victim in the process. The Court applied the established jurisprudence that whenever a homicide has been committed as a consequence or on the occasion of a robbery, all those who took part as principals in the robbery will also be held guilty as principals in the special complex crime of robbery with homicide, even if they did not all actually take part in the homicide. This is unless it appears that those who did not do so endeavored to prevent the homicide. The appellant, upon hearing the victim groaning, did not attempt to prevent the killing and instead fled the scene and hid for two years, demonstrating no effort to prevent the homicide. Thus, he is equally guilty.
Main Doctrine
When conspiracy is proven in a case of robbery with homicide, all those who participated in the robbery will be held guilty of the special complex crime of robbery with homicide, even if not all of them actually took part in the homicide perpetrated by just one of them on the occasion or as a consequence of the asportation, unless they endeavored to prevent the killing.