In People v. Pajotal, the Supreme Court affirmed the conviction of Dindo Pajotal for robbery with homicide, underscoring that if a killing occurs during a robbery, all those involved are held liable for the special complex crime, regardless of who inflicted the fatal blow. This decision clarifies that the primary intent to commit robbery, when coupled with a resulting death, constitutes robbery with homicide, even if the death was not the original intent. The ruling reinforces the principle that participants in a robbery assume the risk for any deaths that occur during its commission, ensuring accountability for violent outcomes during criminal acts. This has significant implications for individuals involved in robberies where death occurs, highlighting the severe legal consequences.

When a Robbery Turns Deadly: Establishing Liability in Joint Criminal Ventures

The case revolves around an incident on October 21, 1996, in Mansalay, Oriental Mindoro, where Winefred Espina, while driving a passenger jeepney, was stopped by three men—Dindo Pajotal, Randy Gabay, and Lindo Gabay. The men, conspiring together, boarded Espina’s jeep with the intent to rob him. During the robbery, Espina was stabbed multiple times, resulting in his death. The assailants took P15,000.00 from him. Dindo Pajotal was apprehended and charged with robbery with homicide, while Randy and Lindo Gabay remained at large. The central legal question is whether Pajotal could be convicted of robbery with homicide given the circumstances of Espina’s death during the robbery.

The Regional Trial Court of Oriental Mindoro found Dindo Pajotal guilty, sentencing him to death based on Article 294, paragraph 1 of the Revised Penal Code, as amended by R.A. 7659, which penalizes robbery with homicide. Pajotal appealed, arguing that his guilt was not proven beyond reasonable doubt and that the crimes committed were separate offenses of simple robbery and homicide, warranting lesser penalties. The Supreme Court, however, found the appeal without merit, emphasizing the direct connection between the robbery and the homicide.

The prosecution’s case rested heavily on the testimony of Arnold Bugayon, Espina’s nephew, who witnessed the crime. Bugayon testified that Pajotal and his companions boarded the jeep with clear intent to rob Espina. Bugayon’s account was crucial in establishing the sequence of events and the involvement of each perpetrator. The defense presented by Pajotal was an alibi, claiming he was at home repairing a fishing device at the time of the incident. However, this alibi was weak due to its failure to prove the impossibility of Pajotal being at the crime scene, especially considering the short distance between his house and the highway where the robbery occurred.

The Supreme Court gave significant weight to Bugayon’s eyewitness account, stating, “A doctrine of long standing in this jurisdiction is that the testimony of a lone eyewitness, if credible and positive, is sufficient to convict an accused.” The Court found Bugayon’s testimony credible and consistent with the medical findings, which corroborated the manner of Espina’s death. This underscored the court’s reliance on direct, credible evidence in affirming Pajotal’s conviction.

In examining whether the crime constituted robbery with homicide, the Supreme Court referenced Article 294, paragraph 1 of the Revised Penal Code, which addresses the circumstances under which homicide committed during a robbery elevates the crime to a special complex offense. The court clarified that the sequence of events—whether the homicide preceded or followed the robbery—does not alter the nature of the crime, as long as there is a direct connection between the two. The court stated:

In order to determine the existence of the crime of robbery with homicide, it is enough that death results by reason or on the occasion of the robbery inasmuch as it is only the result obtained, without reference or distinction as to the circumstances, causes, modes, or persons intervening in the commission of the crime, that has to be taken into consideration.

Building on this principle, the Court emphasized that the primary criminal design must be robbery, with the homicide perpetrated to facilitate or ensure its success. In this case, Espina was stabbed initially to prevent him from resisting the robbery, and further attacked to ensure the robbers’ escape, thus establishing the integral link between the robbery and the homicide.

The Court also addressed the presence of aggravating circumstances. While treachery and evident premeditation were initially alleged, the Court found these inapplicable. However, it upheld the presence of abuse of superior strength, noting the attackers’ numerical advantage and the use of weapons against an unarmed victim. This aggravating circumstance played a crucial role in the imposition of the death penalty, which was the maximum penalty prescribed at the time.

The Supreme Court also addressed the issue of civil indemnities, making some adjustments to the amounts awarded by the trial court. The Court sustained the award of P50,000.00 as civil indemnity and P26,000.00 as actual damages. However, it disallowed the award for loss of earning capacity due to the lack of documentary evidence supporting Espina’s income. The Court noted that, generally, documentary evidence is required to substantiate claims for loss of earning capacity, but there are exceptions for self-employed individuals earning less than the minimum wage. The Court clarified that in this case, the testimony of the victim’s widow was insufficient without supporting documentation, since the victim was earning substantially more than the minimum wage.

Furthermore, the Supreme Court awarded moral damages of P50,000.00, citing relevant provisions of the Civil Code and recent jurisprudence. It also awarded exemplary damages of P20,000.00, pursuant to Article 2230 of the Civil Code, due to the presence of the aggravating circumstance of abuse of superior strength. These awards aimed to provide additional compensation to the victim’s heirs for the suffering and moral injury caused by the crime, and to set an example to deter similar conduct in the future.

The Supreme Court’s decision in People v. Pajotal serves as a reminder of the serious consequences for those involved in robberies where death occurs. The ruling underscores that all participants in a robbery can be held liable for the special complex crime of robbery with homicide, even if they did not directly cause the death. This is particularly relevant in cases involving multiple offenders, as it clarifies the extent of liability and the collective responsibility for the crime. The decision reinforces the principle that intent to commit robbery, coupled with a resulting death, is sufficient to establish guilt for robbery with homicide, ensuring accountability for the violent outcomes of criminal actions.

FAQs

What is robbery with homicide?	Robbery with homicide is a special complex crime where a death occurs by reason or on the occasion of a robbery. This means the death does not need to be the primary intent, but it must be connected to the robbery.
Who is liable in a case of robbery with homicide?	All individuals involved in the robbery can be held liable for robbery with homicide, regardless of who directly caused the death. The critical factor is their participation in the robbery during which the death occurred.
Does it matter if the killing happened before or after the robbery?	No, the timing of the killing (whether before, during, or after the robbery) does not change the nature of the crime. The key is that the death is connected to the robbery, either as a means to commit it or as a result of it.
What evidence is needed to prove robbery with homicide?	The prosecution must prove that a robbery occurred and that a death resulted from or during the robbery. Eyewitness testimony, medical evidence, and confessions are common types of evidence used in these cases.
What is an aggravating circumstance, and how does it affect the penalty?	An aggravating circumstance is a factor that increases the severity of a crime. In this case, abuse of superior strength was an aggravating circumstance, leading to a harsher penalty for the accused.
What are moral damages?	Moral damages are awarded to compensate for the mental anguish, suffering, and emotional distress caused by the crime. These damages are intended to provide some solace to the victim’s family.
What are exemplary damages?	Exemplary damages are awarded to set an example and deter similar conduct in the future. These are often imposed when the crime involves aggravating circumstances.
Why was the award for loss of earning capacity disallowed in this case?	The award was disallowed because there was no documentary evidence presented to prove the victim’s income. While there are exceptions, the victim’s earnings were above the minimum wage, requiring more substantial proof.

This case underscores the severe consequences of engaging in robbery, especially when it results in the loss of life. The Supreme Court’s ruling clarifies the liability of all participants in such crimes and emphasizes the importance of credible evidence in proving guilt and determining appropriate compensation for the victim’s heirs.

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 vs. Pajotal, G.R. No. 142870, November 14, 2001