People v. Madrelejos
REITERATIONFacts
The Antecedents: Accused-appellant Al Madrelejos, along with a John Doe, was charged with robbery with homicide for allegedly robbing and shooting Jovel Federeso Jacaban inside a jeepney on January 22, 2008, in Caloocan City. The information alleged that the accused, armed with a handgun, with intent to gain, by means of force, threats, violence, and intimidation, took a bag belonging to Jovel Federeso Jacaban, and on the occasion of the robbery, shot Jovel Federeso Jacaban, causing his death. Procedural History: The Regional Trial Court (RTC), Branch 128, Caloocan City, found accused-appellant guilty of robbery with homicide and sentenced him to reclusion perpetua, with awards for civil indemnity, moral damages, and exemplary damages. The Court of Appeals (CA) modified the RTC's decision, convicting accused-appellant of attempted robbery with homicide, sentencing him to an indeterminate penalty, and deleting the award for exemplary damages while increasing civil indemnity. The CA ruled that the taking of belongings was not consummated. The Petition: Unsatisfied, accused-appellant appealed to the Supreme Court, arguing that the courts below erred in giving credence to the prosecution's version and in convicting him despite the prosecution's failure to prove his guilt beyond reasonable doubt.
Issue(s)
Whether the accused-appellant is guilty of robbery with homicide, including whether the prosecution proved all elements of the crime. Whether the prosecution proved the element of asportation for robbery. Whether the CA erred in modifying the RTC's conviction to attempted robbery with homicide, and on the propriety of the award of damages.
Ruling
The Supreme Court dismissed the appeal, affirmed the Court of Appeals' decision with modification, and held the accused-appellant guilty of robbery with homicide. The Court ordered the accused-appellant to pay the heirs of Jovel Federeso Jacaban ₱75,000.00 as civil indemnity, ₱75,000.00 as moral damages, ₱75,000.00 as exemplary damages, and ₱50,000.00 as temperate damages, with legal interest.
Ratio Decidendi
On the propriety of conviction for robbery with homicide: The Court reiterated the four elements of robbery with homicide: (1) the taking of personal property with the use of violence or intimidation against the person; (2) the property taken belongs to another; (3) the taking is characterized by intent to gain (animus lucrandi); and (4) on the occasion of the robbery or by reason thereof, the crime of homicide was committed. The Court emphasized that the robbery must be proved as conclusively as any other element. The prosecution must prove the original criminal design to commit robbery, with homicide perpetrated on the occasion or by reason of the robbery. The intent to rob must precede the taking of human life, and the homicide may occur before, during, or after the robbery. The Court found that the intention to rob was evident when the robbers announced the hold-up and was fortified when the companion of the accused-appellant began taking passengers' belongings. The victim, Jovel, was shot while struggling with the accused-appellant's companion over his bag, establishing the nexus between the robbery and the homicide. On the element of asportation: The Court disagreed with the appellate court's finding that asportation was not proven. While it was unclear if Jovel's bag was taken, the testimonies of prosecution witnesses Marina Rubia and Simeon Sidera, Jr. clearly established that the belongings of other passengers were taken. Rubia testified that the accused-appellant's companion proceeded to take the passengers' things, including Jovel's, and that Jovel and the companion were pulling/grabbing the bag. Sidera corroborated this, stating that the accused-appellant's companion was taking the passengers' things. The Court held that even if Jovel's bag was not taken, the successful taking of other passengers' belongings was sufficient to establish the element of asportation for robbery, thus consummating the crime of robbery with homicide. On the modification of the CA's conviction to attempted robbery with homicide and the award of damages: The Court found that the RTC was correct in convicting the accused-appellant of consummated robbery with homicide, not attempted robbery with homicide as ruled by the CA. The evidence presented, particularly the testimonies regarding the taking of other passengers' belongings, proved the consummation of the robbery. Therefore, the CA erred in modifying the conviction based on the perceived lack of consummated asportation. The Court reinstated the RTC's finding of guilt for robbery with homicide. The Court also found it appropriate to adjust the award of damages based on jurisprudence. Citing People v. Jugueta, the Court noted the proper amounts for robbery with homicide: ₱75,000 as civil indemnity, ₱75,000 as moral damages, ₱75,000 as exemplary damages, and ₱50,000 as temperate damages. The CA had deleted exemplary damages and increased civil indemnity. The Supreme Court reinstated the award of exemplary damages and ordered an award of temperate damages, bringing the total awards in line with Jugueta.
Main Doctrine
The crime of robbery with homicide is consummated when there is a taking of personal property with the use of violence or intimidation against persons, the property taken belongs to another, there is intent to gain, and on the occasion of the robbery or by reason thereof, homicide is committed. It is immaterial if the victim of homicide is different from the victim of robbery, or if the taking of all personal properties was not proven, as long as the taking of some property and the commission of homicide on the occasion thereof are established.