The Supreme Court affirmed the conviction of Stanley Buenamer for robbery with homicide, emphasizing that individuals are responsible for all natural and logical consequences of their felonious acts. This decision underscores that even unintended outcomes during the commission of a crime, such as the death of a victim, can lead to severe penalties. This ruling ensures that perpetrators are held fully accountable, reinforcing the principle that actions during a robbery that result in a death will be prosecuted as robbery with homicide, regardless of intent to kill.

When a Hold-Up Turns Deadly: Can a Robber Be Held Liable for Unintentional Homicide?

This case revolves around an incident on October 20, 2009, when Stanley Buenamer and Jerome Lambada staged an armed robbery on a passenger FX taxi in Manila. During the robbery, Ferrarie Tan, a passenger, was killed after Buenamer struck him, causing him to fall from a moving jeepney and be run over. The central legal question is whether Buenamer should be held liable for robbery with homicide, even if the death was not his direct intention. The Regional Trial Court (RTC) found Buenamer guilty of robbery with homicide, while Lambada was convicted of simple robbery. Buenamer appealed, arguing that the prosecution failed to prove his guilt beyond a reasonable doubt and that he had no intention of causing such grave harm.

The Court of Appeals (CA) affirmed the RTC’s decision, emphasizing that all elements of robbery with homicide were present. The CA highlighted that the prosecution successfully proved Buenamer’s identity through eyewitness testimonies. Dissatisfied, Buenamer elevated the case to the Supreme Court, continuing to argue that his actions did not warrant a conviction for robbery with homicide. The Supreme Court, however, upheld the CA’s decision, reinforcing the principle that a person is responsible for the consequences of their actions during the commission of a felony.

The Supreme Court meticulously examined the elements of robbery with homicide, which include: (1) taking personal property with violence or intimidation; (2) the property belongs to another; (3) the taking is with animo lucrandi (intent to gain); and (4) homicide is committed by reason of or on the occasion of the robbery. In this case, the prosecution established that Buenamer and Lambada’s primary objective was to rob the passengers of the FX taxi. David, a passenger and victim, positively identified Buenamer as one of the perpetrators. She testified that Buenamer and Lambada, armed with firearms, announced a hold-up, divested passengers of their belongings, and threatened to kill anyone who resisted. This clearly demonstrated the element of violence and intimidation, coupled with the intent to gain, thus satisfying the first three elements.

The critical point of contention was whether the homicide was directly linked to the robbery. Traffic enforcer Mendez testified that he saw Buenamer strike Ferrarie, causing him to fall from the moving jeepney and subsequently be run over. This direct link between the robbery and the resulting death established the final element of robbery with homicide. Buenamer’s defense hinged on the argument that he did not intend to kill Ferrarie, attempting to invoke the mitigating circumstance of lack of intent to commit so grave a wrong. However, the Court rejected this argument, citing Article 3 of the Revised Penal Code (RPC), which holds individuals responsible for all natural and logical consequences of their felonious acts.

Article 3 of the RPC decrees that every person shall be held responsible for all the natural and logical consequences of his felonious act.

Furthermore, Article 4 of the RPC states that “criminal liability shall be incurred (1) by any person committing a felony, although the wrongful act done be different from that which he intended.” These provisions underscore that even if Buenamer did not intend to kill Ferrarie, his actions during the commission of the robbery directly led to the victim’s death, thereby establishing his liability for robbery with homicide. The Court emphasized that the intention of the offender must be considered in light of the weapon used, the mode of attack, and the injuries sustained by the victim. In this case, the act of striking Ferrarie, which caused him to fall from a moving vehicle and be run over, was deemed a direct and foreseeable consequence of the robbery.

[T]his mitigating circumstance addresses itself to the intention of the offender at the particular moment when the offender executes or commits the criminal act – an intention that must comport, amongst others, with the weapon/s used by the offender and the mode of attack adopted by the latter, vis-a-vis the injuries sustained by his victim.

The Supreme Court cited People v. Gonzalez, Jr., reinforcing that the intention of the accused is manifested by the weapon used, the mode of attack, and the injury sustained by the victim. The manner in which Buenamer struck Ferrarie, leading to his fatal fall, indicated a level of violence that negated any claim of a lack of intent to cause serious harm. The Court highlighted the legal principle that every person is responsible for the natural and logical consequences of their felonious act, as enshrined in Article 3 of the RPC.

Moreover, the ruling serves as a stern reminder of the severe consequences of committing robbery. It clarifies that if a death occurs during or because of a robbery, the perpetrator will be held accountable for robbery with homicide, regardless of whether the death was intentional. This decision reinforces the State’s commitment to protecting its citizens from violent crimes and ensuring that justice is served when such crimes result in loss of life. The Supreme Court’s decision underscores the principle of accountability, ensuring that those who commit felonies are responsible for all resulting harm, even if unintended.

FAQs

What is robbery with homicide?	Robbery with homicide is a crime where the act of robbery results in the death of a person. The death can occur before, during, or after the robbery.
What are the elements of robbery with homicide?	The elements include: (1) taking personal property with violence or intimidation; (2) the property belongs to another; (3) the taking is with intent to gain; and (4) homicide is committed by reason of or on the occasion of the robbery.
Was the death in this case intentional?	The court found that whether the death was intentional or not is irrelevant. Because the death occurred during the commission of robbery, the crime is robbery with homicide.
What is animo lucrandi?	Animo lucrandi is a Latin term meaning intent to gain. It is a key element in proving robbery, as it establishes that the perpetrator’s motive was to profit from the crime.
What does Article 3 of the Revised Penal Code state?	Article 3 of the RPC states that every person is responsible for all the natural and logical consequences of their felonious acts. This means that individuals are liable for the foreseeable outcomes of their criminal behavior.
What damages were awarded in this case?	The appellant was ordered to pay civil damages of P75,000.00, moral damages of P75,000.00, and exemplary damages of P75,000.00.
Why was the mitigating circumstance of lack of intent not applied?	The court determined that the actions of the accused, striking the victim leading to his fall from a moving vehicle, indicated a level of violence that negated any claim of a lack of intent to cause serious harm.
What is the significance of this ruling?	This ruling underscores the severe consequences of committing robbery and clarifies that if a death occurs during or because of a robbery, the perpetrator will be held accountable for robbery with homicide, regardless of intent.

In conclusion, the Supreme Court’s decision in People v. Buenamer reaffirms the principle that individuals are accountable for the consequences of their criminal actions, even if those consequences are unintended. The ruling emphasizes the gravity of robbery with homicide and serves as a deterrent against violent crimes. The court’s unwavering stance on accountability sends a clear message that those who engage in criminal activity will be held responsible for all resulting harm.

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 v. Buenamer, G.R. No. 206227, August 31, 2016