The Supreme Court affirmed the conviction of Joey Aquino and Jose Trinidad for robbery with homicide, emphasizing the principle of conspiratorial liability. The Court underscored that even if only one perpetrator directly caused the death during a robbery, all involved in the conspiracy are equally responsible. This ruling reinforces that participation in a robbery leading to homicide carries severe consequences for all conspirators, not just the one who inflicted the fatal blow.

When a Hold-Up Turns Deadly: Can All Robbers Be Held Accountable for Murder?

In the case of People of the Philippines v. Joey Aquino, the central question revolved around the extent of liability in a robbery that resulted in the death of the victim. On November 13, 1994, Joey Aquino, along with Eduardo Nejal and Jose Trinidad, stormed into a restaurant owned by Gregory Bitmead, announcing a hold-up. During the robbery, Bitmead was shot and killed. While Aquino was identified as the shooter, the prosecution argued that all three accused conspired to commit the crime, making them equally culpable for the resulting homicide. The trial court convicted Aquino and Trinidad of robbery with homicide, while acquitting Nejal due to insufficient evidence of his direct participation. This decision was then elevated to the Supreme Court for automatic review, given the imposition of the death penalty.

The Supreme Court began its analysis by addressing the credibility of the witnesses who identified Aquino and Trinidad as the perpetrators. The Court reiterated that appellate courts generally defer to the trial court’s assessment of witness credibility, as the trial court has the opportunity to observe the witnesses’ demeanor and manner of testifying. In this case, the eyewitnesses—Stefen, Marilou, and Janet—provided consistent and objective accounts of the events they witnessed. The Court found no reason to overturn the trial court’s assessment, emphasizing that the restaurant was well-lit and the witnesses had ample opportunity to observe the perpetrators. The Court quoted People v. Martinez, stating, “when conditions of visibility are favorable and the witnesses do not appear to be biased, their assertions as to the identity of the malefactor should be accepted as truthworthy.” This underscored the importance of clear and unbiased testimony in establishing the identity of the accused.

Furthermore, the Court addressed discrepancies in Stefen’s initial description of Aquino, noting that minor inconsistencies are inconsequential. The Court acknowledged that witnesses often focus on facial features and movements, rather than providing precise measurements of height or other physical attributes. The Court cited People v. Pulusan, emphasizing that victims of violence tend to focus on the perpetrators’ appearance and actions during the crime. Additionally, the Court highlighted the inherent limitations of sworn statements, which are often incomplete or inaccurate due to partial suggestions or lack of thorough inquiries. The critical factor was Stefen’s positive identification of Aquino in open court, supported by her testimony that she had previously seen him and Trinidad at the restaurant prior to the robbery.

Turning to the element of robbery, the Court emphasized that the prosecution must prove the unlawful taking of personal property with intent to gain, achieved through violence or intimidation. Both Stefen and Marilou testified that Aquino took Bitmead’s belt bag containing P20,000, and Stefen herself was robbed of jewelry. The Court stated, “Taking with intent to gain of personal property belonging to another by means of violence against or intimidation of any person or force upon things constitutes robbery.” This established the element of unlawful taking. Although the exact amount taken was not definitively proven, the Court noted that the primary consideration in robbery with homicide is the nexus between the robbery and the killing, regardless of whether the killing occurred before, during, or after the robbery. The Court cited People v. Faco, stressing that “in robbery with homicide, the important consideration is that there be a nexus between the robbery and the killing whether prior, subsequent to or committed at the same time.”

A pivotal aspect of the decision involved the application of conspiracy. The Court underscored the principle that when a homicide is committed by reason or on the occasion of a robbery, all participants are liable as principals of robbery with homicide, even if some did not directly participate in the killing. The Court referenced People v. Lascuna, affirming that “whenever a homicide is committed by reason or on the occasion of a robbery, all those who took part therein are liable as principals of the crime of robbery with homicide, although some did not actually take part in the homicide.” The evidence demonstrated that Aquino, Trinidad, and Nejal acted in concert, with Aquino wielding the armalite and Trinidad and Nejal standing guard with handguns. Even though only Aquino was seen firing the fatal shots, the Court concluded that the conspiracy was adequately established, rendering all conspirators liable as principals. The Court stated, “all the conspirators are liable as principals regardless of the extent of their respective individual participation, for in contemplation of law, the act of one is the act of all,” citing People v. Martinado. This highlights the far-reaching consequences of participating in a conspiracy that results in death, regardless of one’s direct involvement in the act of killing.

The Supreme Court then addressed the penalty imposed by the trial court. The trial court had sentenced Aquino and Trinidad to death. The Supreme Court modified the penalty to reclusion perpetua, because no mitigating or aggravating circumstances were proven during the trial. The Court referenced Article 63 of the Revised Penal Code, which stipulates that when the law prescribes a penalty composed of two indivisible penalties (such as reclusion perpetua to death), and neither mitigating nor aggravating circumstances are present, the lesser penalty shall be applied. The Court’s decision to reduce the penalty underscores the importance of considering mitigating and aggravating circumstances in determining the appropriate punishment for a crime.

The Supreme Court also considered Aquino’s argument that he was denied effective assistance of counsel. The Court dismissed this claim, stating that Aquino was assisted by counsel and had the opportunity to raise any concerns regarding his counsel’s performance during the trial. The Court emphasized that Aquino’s conviction was based on the strength of the prosecution’s case, rather than any perceived weakness in his defense. The Court affirmed that there was no basis for the award of P200,000, and jurisprudence had fixed the indemnity for death at P50,000 without need of proof.

FAQs

What was the key issue in this case?	The key issue was determining the extent of liability for individuals involved in a robbery that resulted in homicide, specifically addressing the principle of conspiratorial liability.
What is robbery with homicide?	Robbery with homicide is a special complex crime under Article 294 of the Revised Penal Code, where a killing occurs by reason or on the occasion of a robbery.
What does conspiratorial liability mean?	Conspiratorial liability means that all individuals who conspired to commit a crime are equally responsible for the acts of any one of them in furtherance of the conspiracy.
What was the court’s ruling on conspiratorial liability in this case?	The court ruled that even if only one person directly caused the death during a robbery, all who conspired to commit the robbery are equally liable for the crime of robbery with homicide.
Why was the death penalty reduced to reclusion perpetua?	The death penalty was reduced because no mitigating or aggravating circumstances were proven during the trial, and the law mandates the lesser penalty in such cases.
How did the court assess the credibility of the witnesses?	The court deferred to the trial court’s assessment of witness credibility, emphasizing that the eyewitnesses provided consistent and objective accounts of the events they witnessed.
What is the significance of proving a nexus between the robbery and the killing?	Proving a nexus is crucial because it establishes the connection between the robbery and the homicide, making the crime a special complex crime of robbery with homicide.
What was the final award of damages in this case?	The court modified the award of damages to P50,000 as indemnity for the death of Gregory Bitmead, consistent with established jurisprudence.

The Supreme Court’s decision in People of the Philippines v. Joey Aquino reaffirms the principle of accountability in robbery with homicide cases. By emphasizing conspiratorial liability and requiring a nexus between the robbery and the killing, the Court ensures that all participants in such crimes are held responsible for their actions. This ruling serves as a reminder that involvement in criminal conspiracies carries significant legal consequences, regardless of one’s direct participation in the 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 of the Philippines vs. Joey Aquino y Acedo, G.R. No. 129288, March 30, 2000