In People vs. Amba, the Supreme Court clarified the elements necessary to prove attempted robbery with homicide, emphasizing the importance of intent and the causal link between the attempted robbery and the resulting death. The Court affirmed the conviction of Jose Ishikawa Amba for this complex crime but adjusted the penalties and damages awarded. This decision underscores that even if a robbery is not completed, the intent to rob coupled with a homicide directly related to that attempt can lead to a conviction for attempted robbery with homicide.

From Snack Stop to Tragedy: Did Intent to Rob Lead to Unlawful Death?

The case revolves around an incident that occurred on February 10, 1998, when Stephanie Sy and her friend Jennifer Llamas were walking to a Seven-Eleven store in Marikina City. As they approached the store, a man attacked Stephanie, attempting to rob her. During the struggle, Stephanie was stabbed and ultimately died from her injuries. Jose Ishikawa Amba was later identified as the assailant and charged with robbery with homicide. The central legal question is whether Amba’s actions constituted attempted robbery with homicide, and if so, what the appropriate penalties should be.

At trial, the prosecution presented eyewitness testimonies from Llamas, Carlos Sian III, and Nelson Almuete, all of whom identified Amba as the perpetrator. Llamas’s testimony was particularly crucial, as she was with Stephanie when the attack occurred. She recounted seeing Amba grab Stephanie, a struggle ensuing, and then Amba stabbing Stephanie. Sian, another eyewitness, corroborated this account, stating that he saw Amba stab a woman across the street. Almuete, Amba’s brother-in-law, also testified, claiming he witnessed Amba following and attacking Stephanie.

Amba, in his defense, claimed alibi, stating that he was at work in San Juan at the time of the incident. He also challenged the credibility of the eyewitnesses, arguing that their testimonies were conflicting and influenced by police procedures, such as being shown photographs of him before identification. However, the trial court found the testimonies of the prosecution witnesses to be credible and convicted Amba of attempted robbery with homicide. The court also appreciated the qualifying circumstances of treachery and abuse of superior strength.

The Supreme Court, in reviewing the case, upheld the conviction but modified the lower court’s decision. The Court emphasized the importance of the trial court’s assessment of witness credibility, stating that appellate courts should not disturb these findings unless there is clear evidence that the trial court overlooked significant facts. As the Supreme Court stated in People vs. Sagun, “Appellate courts will not disturb the findings on the credibility, or lack of it, accorded by the trial court to the testimony of witnesses, unless it be clearly shown that the trial court had overlooked or disregarded arbitrarily certain facts and circumstances of significance in the case.” The Court found the eyewitness testimonies to be consistent and convincing, supporting the conclusion that Amba was indeed the assailant.

The Court then addressed the elements of robbery with homicide, referencing People vs. Faco, which stated that to be liable, the prosecution must establish: “(a) the taking of the personal property with the use of violence or intimidation against a person; (b) the property thus taken belongs to another; (c) the taking is characterized by intent to gain or animus lucrandi; and (d) on the occasion of the robbery or by reason thereof, the crime of homicide, which therein used in a generic sense, was committed.” The Court noted that while it was not definitively proven what Amba intended to steal, his actions clearly indicated an intent to rob Stephanie. The crime was not completed due to Stephanie’s resistance, thus constituting attempted robbery.

However, the Supreme Court disagreed with the trial court’s assessment that treachery and abuse of superior strength were present. Treachery, as defined in People vs. Cabareño, requires that “the means, method or form of execution gives the person attacked no opportunity for self-defense or retaliation.” The Court found that Stephanie had, in fact, struggled against Amba and even managed to kick him, indicating that she had an opportunity for self-defense. Therefore, the element of treachery was not present.

Consequently, the Court adjusted the penalty. Article 297 of the Revised Penal Code governs attempted robbery with homicide and prescribes a penalty of reclusion temporal in its maximum period to reclusion perpetua. Because there were no aggravating or mitigating circumstances, the Court applied the Indeterminate Sentence Law, sentencing Amba to an indeterminate penalty of 14 years and eight months of prision mayor as minimum to 20 years of reclusion temporal as maximum.

Finally, the Court modified the damages awarded. While the P50,000 indemnity for death and P75,000 for funeral expenses were upheld, the P150,000 for moral and exemplary damages was adjusted. Citing prevailing jurisprudence, the Court reduced the moral damages to P50,000. It denied the award for exemplary damages, as Article 2231 of the Civil Code stipulates that such damages are only awarded when the crime is committed with one or more aggravating circumstances, which were not present in this case. Therefore, the final award included P50,000 for death indemnity, P50,000 for moral damages, and P75,000 for funeral expenses.

FAQs

What was the key issue in this case?	The key issue was whether Jose Ishikawa Amba was guilty of attempted robbery with homicide in the death of Stephanie Sy, and what the appropriate penalties and damages should be. The Court needed to determine if the elements of the crime were met and if the qualifying circumstances of treachery and abuse of superior strength were applicable.
What is attempted robbery with homicide?	Attempted robbery with homicide is a complex crime where the offender attempts to commit robbery, and on the occasion or by reason of such attempt, a homicide occurs. It requires proving intent to rob along with the causal connection between the attempted robbery and the resulting death.
What evidence did the prosecution present?	The prosecution presented eyewitness testimonies from Jennifer Llamas, Carlos Sian III, and Nelson Almuete, all of whom identified Jose Ishikawa Amba as the assailant. They also presented documentary evidence and expert testimony from the Medico Legal Officer.
What was the accused’s defense?	Jose Ishikawa Amba claimed alibi, stating that he was at work at the time of the incident. He also challenged the credibility of the eyewitnesses, arguing that their testimonies were conflicting and influenced by police procedures.
Did the Supreme Court agree with the trial court’s findings on treachery?	No, the Supreme Court disagreed with the trial court’s finding that treachery was present. The Court noted that Stephanie Sy had struggled against Amba, indicating that she had an opportunity for self-defense, which negated the element of treachery.
How did the Supreme Court modify the penalty?	The Supreme Court applied the Indeterminate Sentence Law, sentencing Amba to an indeterminate penalty of 14 years and eight months of prision mayor as minimum to 20 years of reclusion temporal as maximum. This replaced the trial court’s original sentence of reclusion perpetua.
What damages were awarded in this case?	The Supreme Court awarded P50,000 for death indemnity, P50,000 for moral damages, and P75,000 for funeral expenses to the heirs of Stephanie Sy. The original award of P150,000 as moral and exemplary damages was adjusted.
What is the significance of establishing intent to rob?	Establishing intent to rob (animus lucrandi) is crucial because it is a key element of the crime of robbery with homicide. Without proving that the accused intended to gain from the victim, the charge of robbery with homicide cannot be sustained.

In conclusion, the People vs. Amba case serves as an important reminder of the legal consequences of attempted robbery when it results in death. The Supreme Court’s decision clarifies the elements necessary to prove this complex crime and underscores the significance of intent and causation in determining liability. The adjustment of penalties and damages further highlights the Court’s careful consideration of the circumstances surrounding the crime.

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. Amba, G.R. No. 140898, September 20, 2001