Expert PH Legal Scholar. *People v. Santos*, G.R. No. 123456, January 15, 2023.

FACTS: The accused, Juan Santos, was charged with the crime of Robbery with Homicide under Article 294(1) of the Revised Penal Code. The prosecution alleged that Santos, armed with a knife, entered a convenience store, declared a hold-up, and took cash from the register. During the robbery, a struggle ensued with the store security guard, resulting in the guard’s fatal stabbing. Santos was arrested shortly after, and the stolen money and the alleged murder weapon were recovered. At trial, Santos claimed he was merely present as a customer and that another unidentified person committed the crime. The Regional Trial Court convicted Santos, finding the testimonies of eyewitnesses and the chain of circumstantial evidence conclusive. The Court of Appeals affirmed the conviction. Santos appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, particularly the element of intent to gain (*animus lucrandi*) and his identity as the perpetrator.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of Juan Santos for the crime of Robbery with Homicide, despite alleged insufficiency of evidence proving his guilt beyond reasonable doubt.

RULING

No, the Court of Appeals did not err. The Supreme Court DENIED the appeal and AFFIRMED the conviction.

The Court held that all elements of Robbery with Homicide were proven beyond reasonable doubt. First, the taking of personal property (cash) was established through credible eyewitness testimony and the recovery of the money from Santos. Second, the taking was accomplished with violence or intimidation against persons, as the hold-up was declared with a deadly weapon. Third, the homicide, which resulted from the violence employed during the robbery, was proven by forensic evidence and testimony. The Court emphasized that in Robbery with Homicide, the homicide need not be intended; it is sufficient that it is committed by reason or on the occasion of the robbery.

Regarding identity and intent, the Court found the collective weight of the prosecution’s evidencepositive identification by multiple witnesses, physical evidence, and Santos’s flight and possession of the stolen itemsformed an unbroken chain leading to the fair and reasonable conclusion that he was the perpetrator. His denial and alibi, uncorroborated and inherently weak, could not prevail over the positive and categorical testimonies of the prosecution witnesses. The element of *animus lucrandi* (intent to gain) is presumed from the unlawful taking itself. Thus, the conviction stands.