G.R. Nos. 90672-73; July 18, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLANDO MARANION Y HASAN, ARSENIO RAGUDO Y SUYAT and PAT. ANTONIO BENITO, accused. ROLANDO MARANION Y HASAN, accused-appellant.

FACTS

On July 27, 1980, accused Rolando Maranion, Patrolman Antonio Benito, and Arsenio Ragudo robbed the Santolan Variety Mart in Pasig. Maranion first arrived at the store, acting as a lookout. Benito then entered, announced the hold-up, and with Maranion’s help in closing the store door, herded the store owner’s wife, Margarita See Chi, and two maids into a room. During the robbery, the store owner, William See Chi, and a customer, Sotero de la Cruz, were shot and killed. The robbers fled with P6,200.00, boarding a taxi driven by Ragudo. Separate informations for Robbery by a Band with Double Homicide and Illegal Possession of Firearms were filed. Only Maranion and Ragudo were tried, as Benito remained at large.
The prosecution presented eyewitnesses who positively identified Maranion’s presence and participation. Margarita See Chi and maid Susana Tonido testified to Maranion’s actions before and during the robbery. Ramona de la Cruz Guiang witnessed two men fleeing the scene after the gunshots, one of whom she identified as Maranion, and saw them board Ragudo’s taxi. The trial court convicted Maranion as a principal and Ragudo as an accomplice in the complex crime of Robbery with Homicide, sentencing Maranion to reclusion perpetua. Maranion appealed.

ISSUE

Whether accused-appellant Rolando Maranion is liable for the killings as a principal in the special complex crime of Robbery with Homicide, despite not being the actual triggerman.

RULING

Yes. The Supreme Court affirmed the conviction. The legal logic rests on the doctrine of conspiracy. Where conspiracy to commit robbery is established, as it was here through Maranion’s coordinated actions as a lookout and participant, all conspirators are equally liable for all acts committed in furtherance of the conspiracy, including homicides. The crime committed is the special complex crime of Robbery with Homicide under Article 294(1) of the Revised Penal Code, as the killings were directly linked to and occurred during the robbery. The degree of actual participation in the killing is immaterial; a conspirator is liable for the acts of co-conspirators. The Court emphasized that in this complex crime, the number of persons killed does not alter the penalty or denomination of the offense; hence, it is simply “Robbery with Homicide,” not “Double Homicide.” Since the evidence showed Maranion did nothing to prevent the killings, his liability as a principal stands. The civil indemnity was increased to P50,000.00 for each victim.