G.R. No. L-31226 September 30, 1982
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FRANCISCO BELLO, EULOGIO SAN JUAN and FLORENCIO MANGUBAT, defendants-appellants.
FACTS
Accused Francisco Bello and Eulogio San Juan, both Bureau of Internal Revenue agents, entered the Jet Snack Restaurant at the Manila International Airport. They searched the premises, found blue seal cigarettes, and confronted the owner, Mrs. Wong Ley Shee, threatening to take her to the BIR for investigation. Mrs. Wong, who was elderly, illiterate, and in poor health, pleaded not to be taken. Bello physically pulled her, causing her great distress and nervousness. She collapsed, was brought to a hospital, and died the next day from a cerebral hemorrhage secondary to hypertension, triggered by the fright and stress of the incident. Meanwhile, the agents detained her son, Wong See Yuen, Jr., and extorted P2,400.00 from him as a condition for his release and for not pursuing charges over the cigarettes.
ISSUE
Whether the accused are guilty of the complex crime of robbery with homicide.
RULING
No. The Supreme Court modified the trial court’s decision. The legal logic is that for the complex crime of robbery with homicide to exist, the killing must be a direct consequence of the robbery or committed in the course of its execution. Here, the Court found no direct causal link between the illegal exaction (robbery through intimidation) and Mrs. Wong’s death. Her death resulted from a pre-existing hypertensive condition aggravated by the fright caused by the agents’ lawful act of investigation and arrest, not by an unlawful act intended to facilitate the robbery. The extortion of money from her son was a separate and subsequent act. Thus, the elements of the complex crime were not satisfied. Consequently, Bello and San Juan were convicted only of the simple crime of robbery through intimidation, with the aggravating circumstance of abuse of public office. Accused Florencio Mangubat was acquitted due to lack of evidence proving conspiracy or accomplice liability.