Title
Ablaza y Caparas vs. People
Case
G.R. No. 217722
Decision Date
Sep 26, 2018
Rosario Snyder’s necklaces were snatched by motorcycle riders in Olongapo City. Identified by photos, Jomar Ablaza and Jay Lauzon were convicted; Supreme Court reclassified the crime as theft, not robbery, due to lack of violence evidence.

Case Digest (G.R. No. 27234)
Expanded Legal Reasoning Model

Facts:

  • Criminal Information and Pleas
    • On July 29, 2010, in Olongapo City, Jomar Ablaza y Caparas (petitioner) and Jay Lauzon y Farrales were charged under Article 294(5) of the Revised Penal Code for conspiring to grab and carry away three necklaces belonging to Rosario S. Snyder, valued at ₱70,100.00.
    • Both accused pleaded not guilty; Lauzon adopted the pre-trial proceedings of Ablaza.
  • Prosecution and Defense Evidence
    • Victim’s Testimony (Rosario S. Snyder)
      • At about 8:30 a.m., while walking on Jolo Street, a two-man motorcycle stopped beside her. The backrider suddenly grabbed her three necklaces, they glanced back at her (unhelmeted), she shouted, and they fled.
      • She identified Ablaza from photographs shown at the police station immediately after the incident, then helped apprehend Lauzon hiding at Ablaza’s house. The necklaces were not recovered.
    • Petitioner’s Defense
      • Ablaza claimed he and Lauzon were asleep after a drinking spree; was misidentified as “tisoy” with tattoos; did not know Snyder; was arrested two months later; admitted prior robbery/theft cases.
  • Lower Court Decisions
    • Regional Trial Court (December 3, 2013)
– Found Snyder credible (candid, clear, coherent), all elements of robbery and conspiracy proven; sentenced both to prision correccional to prision mayor, ordered them to pay ₱70,100.00 with 6% interest and costs.
  • Court of Appeals (March 20, 2015)
– Affirmed conviction; modified maximum penalty to prision mayor and clarified interest accrual from finality of judgment.

Issues:

  • Was Ablaza proven guilty beyond reasonable doubt of Robbery with Violence Against or Intimidation of Persons under Article 294(5) RPC?
  • Should the proper conviction be theft rather than robbery?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.