GR 225328; (March, 2018) (Digest)
G.R. No. 225328. March 21, 2018
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. AL MADRELEJOS Y QUILILAN, ACCUSED-APPELLANT.
FACTS
Accused-appellant Al Madrelejos was charged with Robbery with Homicide. The prosecution evidence established that on January 22, 2008, inside a jeepney in Caloocan City, Madrelejos and a companion declared a hold-up. They ordered passengers to surrender their belongings. The victim, Jovel Jacaban, resisted and refused to give his bag. Madrelejos then shot Jacaban, who later died. The accused and his companion fled the scene.
The defense presented a different version. Madrelejos admitted being on the jeepney and shooting Jacaban but claimed it was accidental. He testified that he grappled for a gun with a personal enemy on board, and the firearm discharged, hitting Jacaban. He denied any intent to rob the passengers.
ISSUE
Whether the Court of Appeals erred in convicting accused-appellant of Attempted Robbery with Homicide.
RULING
The Supreme Court reversed the CA and reinstated the conviction for the consummated special complex crime of Robbery with Homicide. The legal logic hinges on the established elements of the crime and the sequence of events. For Robbery with Homicide, the taking of personal property through violence or intimidation must be proven, and a homicide must occur by reason or on the occasion of the robbery. The intent to commit robbery must precede the homicide.
The Court found the prosecution’s version credible and consistent. Witness testimonies confirmed that the hold-up was declared, intimidation was employed to take belongings, and the shooting occurred when the victim resisted during this ongoing robbery. The fact that the victim’s own bag may not have been successfully taken is immaterial, as the robbery against other passengers was consummated. The homicide was directly occasioned by the robbery, as the shooting was the violent response to the victim’s resistance during the felonious taking. The defense of accidental shooting was rejected for being inconsistent with the evidence of a declared hold-up. The Court modified the damages awarded in accordance with prevailing jurisprudence.