The Supreme Court affirmed the conviction of Wilfredo Layug and Noel Buan for robbery with homicide, emphasizing that when a homicide occurs by reason or on the occasion of robbery, all participants are held liable as principals, regardless of direct involvement in the killing. This ruling underscores the principle that individuals involved in a conspiracy to commit robbery are responsible for the resulting consequences, including unintended deaths, unless they actively attempted to prevent the homicide. This reinforces the severity of engaging in criminal activities where the potential for violence is present, ensuring accountability for all foreseeable outcomes.

When a Hold-Up Turns Deadly: Who Pays the Price?

This case revolves around the tragic death of Victorino Paule, who was robbed and murdered after a shabu session involving appellants Wilfredo Layug and Noel Buan, along with Reynaldo Langit and Analiza Paule, a state witness. Analiza testified that she overheard Reynaldo instructing Wilfredo and Noel about a “hold-up” during their drug session. Subsequently, after spending time with Victorino, Analiza brought him to Wilfredo’s house, where the appellants and Reynaldo were present. The group then took Victorino to a secluded location where he was stabbed and robbed, resulting in his death. The central legal question is whether Wilfredo and Noel are guilty beyond reasonable doubt of robbery with homicide, considering Analiza’s testimony and their defense of denial.

The Regional Trial Court (RTC) found Wilfredo, Noel, and Reynaldo guilty beyond reasonable doubt of robbery with homicide, aggravated by treachery, evident premeditation, and taking advantage of superior strength. The Court of Appeals (CA) affirmed the RTC’s decision but modified the award of damages. Appellants Wilfredo and Noel appealed, arguing that the prosecution failed to prove their guilt beyond a reasonable doubt and that the aggravating circumstances were improperly considered. They questioned the credibility of the prosecution witnesses, particularly Analiza, whose testimony formed the backbone of the prosecution’s case.

The Supreme Court reiterated the principle that it generally defers to the trial court’s factual findings and evaluation of the credibility of witnesses, especially when affirmed by the CA. This deference is rooted in the trial court’s unique position to observe the demeanor of the witnesses and assess their truthfulness. The Court emphasized that positive identification by witnesses, when categorical and consistent, prevails over the defenses of denial and alibi, especially when the defense is unsubstantiated by clear and convincing evidence. In this case, Analiza’s testimony was deemed credible and sufficient to establish the appellants’ participation in the crime.

The Supreme Court thoroughly examined the elements of robbery with homicide, referring to the case of People v. Ebet, which cited People v. De Jesus:

Article 294, paragraph 1 of the Revised Penal Code provides:

Art. 294. Robbery with violence against or intimidation of persons – Penalties. – Any person guilty of robbery with the use of violence against or any person shall suffer:

The penalty of reclusion perpetua to death, when by reason or on occasion of the robbery, the crime of homicide shall have been committed, or when the robbery shall have been accompanied by rape or intentional mutilation or arson.

The elements of robbery with homicide are: (1) the taking of personal property is committed with violence or intimidation against persons; (2) the property taken belongs to another; (3) the taking is animo lucrandi (with intent to gain); and (4) by reason of the robbery or on the occasion thereof, homicide is committed. The Court emphasized that the intent to commit robbery must precede the taking of human life, and the homicide may occur before, during, or after the robbery. The crime is robbery with homicide regardless of how the death occurs, who the victim is, or whether other crimes are committed during the robbery.

In this case, the prosecution proved beyond reasonable doubt that the appellants took Victorino’s personal properties with intent to gain, and that the homicide was committed by reason or on the occasion of the robbery. The Court highlighted Analiza’s testimony, which established that the appellants forcibly took Victorino’s belongings while repeatedly stabbing him, leading to his death. The presence of all the essential elements confirmed the commission of robbery with homicide.

Regarding the aggravating circumstances, the Court clarified that treachery is not a qualifying circumstance in robbery with homicide but a generic aggravating circumstance that increases the penalty. Treachery exists when the offender employs means, methods, or forms in the execution of the crime that tend directly and specially to ensure its execution, without risk to himself arising from the defense which the offended party might make.

The Court referenced People v. Baron:

As thoroughly discussed in People v. Escote, Jr., treachery is not a qualifying circumstance but “a generic aggravating circumstance to robbery with homicide although said crime is classified as a crime against property and a single and indivisible crime”.

In this case, treachery was evident as Victorino was caught off-guard when he was suddenly stabbed by Buan shortly after alighting from the tricycle, giving him no opportunity to defend himself. The Court noted that evident premeditation, on the other hand, is inherent in crimes against property and cannot be appreciated as an aggravating circumstance in robbery with homicide.

The penalty imposed by the RTC—reclusion perpetua—was deemed correct, considering the suspension of the death penalty under Republic Act No. 9346. The Court also addressed the award of damages, deeming it proper to award exemplary damages due to the highly reprehensible conduct of the offenders. Exemplary damages are awarded not only for the presence of aggravating circumstances but also when the offender’s conduct is particularly outrageous.

The Supreme Court affirmed the decision of the Court of Appeals, finding Wilfredo Layug and Noel Buan guilty of robbery with homicide. The Court ordered them to pay, jointly and severally, the heirs of the victim the amount of P100,000.00 as exemplary damages, in addition to the damages awarded by the Court of Appeals, with legal interest on all damages at the rate of six percent (6%) per annum from the date of finality of the decision until fully paid. This ruling reinforces the principle that individuals involved in robbery resulting in death will be held fully accountable for their actions, with significant penalties and damages imposed to compensate the victim’s heirs and deter similar crimes.

FAQs

What is robbery with homicide?	Robbery with homicide is a crime where the taking of personal property is committed with violence or intimidation against persons, and by reason or on the occasion of the robbery, a homicide is committed. The intent to commit robbery must precede the taking of human life.
What are the elements of robbery with homicide?	The elements are: (1) taking of personal property with violence or intimidation; (2) the property belongs to another; (3) the taking is with intent to gain (animo lucrandi); and (4) homicide is committed by reason or on the occasion of the robbery.
Is treachery a qualifying circumstance in robbery with homicide?	No, treachery is not a qualifying circumstance but a generic aggravating circumstance in robbery with homicide. It increases the penalty when the victim is killed treacherously, meaning the attack was sudden and unexpected, depriving the victim of the chance to defend themselves.
What is the significance of intent in robbery with homicide?	The intent to commit robbery must precede the taking of human life. The homicide may occur before, during, or after the robbery, but it must be connected to the robbery for the crime to be considered robbery with homicide.
What is the penalty for robbery with homicide?	The penalty is reclusion perpetua to death. However, the death penalty has been suspended in the Philippines by Republic Act No. 9346, so the penalty imposed is typically reclusion perpetua.
What are exemplary damages?	Exemplary damages are awarded as a form of punishment for the offender’s reprehensible conduct. They serve to deter others from committing similar acts and are awarded in addition to civil indemnity, moral damages, and temperate damages.
Why is the credibility of witnesses important in these cases?	The credibility of witnesses is crucial because their testimonies often provide direct evidence of the crime. Courts give significant weight to the trial court’s assessment of witness credibility, as the trial court has the opportunity to observe their demeanor and assess their truthfulness.
What happens if a conspirator did not directly participate in the killing?	All those who conspire to commit robbery with homicide are guilty as principals, even if they did not directly participate in the killing, unless they clearly endeavored to prevent the homicide. This underscores the principle of shared responsibility in criminal conspiracies.

This case illustrates the severe consequences of engaging in criminal activities that lead to violence and death. The Supreme Court’s decision underscores the importance of holding all participants accountable for their actions, ensuring that justice is served and that the families of victims receive the compensation they deserve.

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 OF THE PHILIPPINES vs. WILFREDO LAYUG, et al., G.R. No. 223679, September 27, 2017