People v. Buenamer
REITERATIONFacts
The Antecedents: On October 20, 2009, accused-appellant Stanley Buenamer y Mandane and his co-accused Jerome Lambada staged an armed robbery inside a passenger FX taxi. They boarded the vehicle, announced a hold-up, and pointed guns at the passengers, demanding their valuables. The victim, Ferrarie Tan, a passenger, pleaded that he had already surrendered his belongings but was still divested of his possessions. When the FX stopped, the victim attempted to chase the robbers who had transferred to a jeepney. While holding onto the jeepney's handle bar in an attempt to retrieve his belongings, Buenamer boxed the victim, causing him to lose his grip and fall. The victim was then run over by the rear tire of the jeepney, sustaining fatal injuries. Procedural History: The Regional Trial Court (RTC) of Manila, Branch 33, found Buenamer guilty beyond reasonable doubt of robbery with homicide and sentenced him to reclusion perpetua. His co-accused, Lambada, was found guilty of simple robbery. The RTC ordered them to pay the value of the stolen items and awarded civil indemnity and moral damages to the victim's heirs. The Court of Appeals (CA) affirmed the RTC's decision with modification, increasing the civil damages and ordering the payment of moral damages. Buenamer appealed to the Supreme Court, arguing insufficient identification and the applicability of a mitigating circumstance. The Petition: The accused-appellant contended that the prosecution failed to establish his identity as the perpetrator beyond reasonable doubt and that the mitigating circumstance of lack of intent to commit so grave a wrong should have been appreciated in his favor, as he did not intend to kill the victim when he boxed him.
Issue(s)
Whether the prosecution sufficiently established the identity of the accused-appellant as one of the perpetrators of the robbery with homicide. Whether the mitigating circumstance of lack of intent to commit so grave a wrong as that committed is applicable to the accused-appellant.
Ruling
The Supreme Court dismissed the appeal, affirming the decision of the Court of Appeals with modification. The accused-appellant Stanley Buenamer y Mandane was found guilty beyond reasonable doubt of the crime of robbery with homicide and sentenced to suffer the penalty of reclusion perpetua. He was ordered to pay the heirs of Ferrarie Tan moral damages in the amount of ₱75,000.00 and exemplary damages of ₱75,000.00. The award of civil damages in the amount of ₱75,000.00 was maintained. All monetary awards shall earn interest at the rate of 6% per annum from the finality of the decision.
Ratio Decidendi
On the issue of identity: The Court held that the prosecution sufficiently established the identity of the accused-appellant. Prosecution witness Diana David, a co-passenger in the FX taxi, positively identified Buenamer as one of the robbers. She testified that she saw his face when they boarded the vehicle and during the commission of the crime. Furthermore, traffic enforcer James Mendez corroborated David's testimony by identifying Buenamer as the person who boxed the victim, Ferrarie Tan, causing him to fall from the jeepney. Mendez was in a position to clearly see the perpetrator due to his proximity to the incident. The testimonies of these eyewitnesses were found to be clear and convincing, establishing Buenamer's participation in the robbery. On the applicability of the mitigating circumstance of lack of intent to commit so grave a wrong: The Court ruled that this mitigating circumstance is not applicable to Buenamer. The Court reiterated that this circumstance requires a notable disparity between the means employed and the resulting crime, and the intention of the accused is manifested from the weapon used, the mode of attack, and the injury sustained by the victim. In this case, Buenamer boxed the victim with such force that it caused him to lose his grip and fall, leading to him being run over by the jeepney's rear tire and his subsequent death. The Court invoked Articles 3 and 4 of the Revised Penal Code, stating that every person is responsible for the natural and logical consequences of his felonious act, even if the wrongful act done be different from that which he intended. The death of Ferrarie Tan was a direct and foreseeable consequence of Buenamer's violent act during the commission of the robbery.
Main Doctrine
The crime of robbery with homicide is committed when personal property is taken with violence or intimidation against persons, with intent to gain, and by reason of the robbery, or on the occasion thereof, homicide is committed. The accused is responsible for all the natural and logical consequences of his felonious act, even if the wrongful act done be different from that which he intended.