Accountability for Robbery with Homicide: All Participants are Principals

G.R. No. 119696, August 18, 1997

Imagine a scenario: a group plans a robbery, but during the act, one of them unexpectedly kills someone. Are all involved equally guilty, even if they didn’t pull the trigger? Philippine law says yes, highlighting the severe consequences of participating in a robbery that results in death.

This principle was firmly established in the case of People v. Razul Guiamil y Angkat and Maguid y Kontier. The Supreme Court affirmed that in robbery with homicide, all participants are held accountable as principals, regardless of whether they directly participated in the killing. This underscores the gravity of the crime and the broad scope of liability.

The Legal Framework of Robbery with Homicide

Robbery with homicide is a special complex crime under Philippine law, specifically defined and penalized under Article 294 of the Revised Penal Code. It’s not simply robbery and homicide occurring separately; it’s a single, indivisible offense where the homicide is committed “on the occasion” or “by reason” of the robbery.

Here are the key elements the prosecution must prove beyond reasonable doubt:

• Taking of personal property: The accused must have taken personal property.
• Violence or intimidation: The taking must have been accomplished through violence against or intimidation of persons, or force upon things.
• Belonging to another: The property taken must belong to someone other than the accused.
• Intent to gain: The taking must have been done with animo lucrandi, meaning with intent to profit.
• Homicide: On the occasion of the robbery, or by reason thereof, a homicide (death) was committed.

Article 294 of the Revised Penal Code states:

“Art. 294. Robbery with homicide. — Any person guilty of robbery with the use of violence against or intimidation of any person shall suffer: 1. The penalty of reclusion perpetua to death, when by reason or on occasion of the robbery, the crime of homicide shall have been committed…”

The crucial point is the connection between the robbery and the homicide. The homicide doesn’t need to be planned; it’s enough that it occurred during the robbery. This legal principle ensures that those who participate in violent robberies are held responsible for the potential deadly outcomes.

The Lucky Jewelry Store Robbery: A Case of Shared Liability

The case unfolded on May 31, 1993, at the Lucky Jewelry Store in Manila. Razul Guiamil, Abedin Maguid, and an unidentified accomplice stormed the store in broad daylight. Maguid shattered the glass display window, and the trio grabbed jewelry worth a staggering P1,200,000.

As Claude Masupil, a store employee, bravely tried to stop them, Maguid fatally shot him. The police swiftly responded, leading to a chase where Maguid was wounded and apprehended. Guiamil was also caught nearby. Masupil’s autopsy revealed he died from hypovolemic shock due to the gunshot wound.

The legal journey of the case involved several key steps:

1. The Regional Trial Court of Manila convicted Guiamil and Maguid of robbery with homicide.
2. They were sentenced to reclusion perpetua (life imprisonment) and ordered to pay P50,000 in civil indemnity and P50,000 for funeral expenses to the victim’s heirs.
3. Guiamil and Maguid appealed, arguing reasonable doubt and inconsistencies in the prosecution’s evidence.
4. The Supreme Court ultimately upheld the lower court’s decision, solidifying their conviction.

The Supreme Court emphasized the clear testimonies of eyewitnesses who positively identified Guiamil and Maguid as the perpetrators. The Court stated, “The matter of assigning values to declarations at the witness stand is best and most completely performed or carried out by a trial judge who, unlike appellate magistrates, can weigh such testimonies in the light of defendant’s behavior, demeanor, conduct and attitude at the trial…”

Furthermore, the Court quoted, “In weighing contradictory declarations and statements, greater weight must generally be given to the positive testimony of the prosecution witnesses than to the denials of the defendant.”

Practical Lessons for Business Owners and Individuals

This case serves as a stark reminder of the legal consequences of participating in a robbery, even if you don’t directly commit the killing. The principle of shared liability means that everyone involved can face the maximum penalty.

Here’s what you should keep in mind:

• Avoid involvement in any criminal activity, especially robbery. The potential consequences are severe, including life imprisonment.
• If you witness a robbery, prioritize your safety and report it to the authorities immediately.
• Business owners should invest in security measures to deter robberies, such as security cameras, alarms, and security personnel.

Key Lessons

• Participation in a robbery that results in death carries severe consequences for all involved, regardless of who committed the homicide.
• Eyewitness testimony is crucial in robbery with homicide cases.
• Denial is a weak defense against strong evidence and credible witnesses.

Frequently Asked Questions

What is the penalty for robbery with homicide in the Philippines?

The penalty is reclusion perpetua to death, depending on the presence of aggravating circumstances.

If I participate in a robbery but don’t know that someone will be killed, am I still liable for robbery with homicide?

Yes. The law states that if a homicide occurs “on the occasion” or “by reason” of the robbery, all participants are liable, regardless of their knowledge or intent regarding the killing.

What is reclusion perpetua?

Reclusion perpetua is a Philippine prison term for life imprisonment.

What should I do if I am accused of robbery with homicide?

Immediately seek legal counsel from a qualified attorney. It’s crucial to understand your rights and build a strong defense.

Can the testimony of a single eyewitness be enough to convict someone of robbery with homicide?

Yes, if the testimony is clear, credible, and consistent with the other evidence presented.

What is the difference between robbery with homicide and murder?

Robbery with homicide is a special complex crime where the homicide is committed during or because of the robbery. Murder is the unlawful killing of another person with malice aforethought.

What is the importance of security measures for businesses?

Security measures can deter robberies and protect employees and customers. They can also provide valuable evidence in case a robbery occurs.

ASG Law specializes in criminal defense and corporate security. Contact us or email hello@asglawpartners.com to schedule a consultation.