Case Digest (G.R. No. 200922)
Facts:
This case involves the accused Cesar Concepcion y Bulanio (Concepcion) who was charged with robbery with homicide under Article 294 of the Revised Penal Code (RPC). The incident occurred on or about May 25, 2004, in Quezon City, Philippines. Concepcion, allegedly conspiring with his co-accused Rosendo Ogardo Jr. y Villegas (Ogardo), forcibly took the shoulder bag of complainant Jennifer Acampado y Quimpo (Acampado), which contained items valued at ₱3,000. The crime allegedly happened while Acampado was walking along Panay Avenue corner Timog Avenue in Barangay Paligsahan. Ogardo, who was driving the motorcycle on which Concepcion was riding, died in a vehicular accident caused by losing control of the motorcycle during a chase with a taxi. The Regional Trial Court (RTC) of Quezon City Branch 81 found Concepcion guilty beyond reasonable doubt of robbery with homicide and sentenced him to reclusion perpetua and ordered reimbursement to Acampado. The Court of Appeals (CA) affirmed
Case Digest (G.R. No. 200922)
Facts:
- Parties and Nature of the Case
- The case involves the People of the Philippines as appellee and Cesar Concepcion y Bulanio (Concepcion) as appellant.
- Concepcion was charged with robbery with homicide under Article 294 of the Revised Penal Code (RPC).
- Circumstances of the Crime
- The incident occurred on or about May 25, 2004, along Panay Avenue corner Timog Avenue, Barangay Paligsahan, Quezon City.
- Concepcion, with intent to gain and in conspiracy with his co-accused Rosendo Ogardo, Jr. y Villegas (Ogardo), forcibly took the shoulder bag of Jennifer Acampado y Quimpo (Acampado) containing various items valued at P3,000.00.
- Acampado was walking when the accused suddenly appeared behind her riding a Suzuki motorcycle (Plate no. RG-7037).
- During the escape, Ogardo died due to a vehicular accident, losing control of the motorcycle and crashing into a taxi.
- Prosecution's Version of Facts
- At approximately 11:00 A.M., Acampado was at a street corner in Quezon City when a man riding at the back of a motorcycle snatched her brown Avon bag.
- The motorcycle sped away; the accused waved the bag tauntingly before escaping.
- A taxi driver, Joemar de Felipe, witnessed the snatching and chased the motorcycle while blowing his horn.
- A vehicular accident occurred causing both occupants of the motorcycle to fall; Ogardo was fatally injured and later died at a hospital.
- Defense’s Version of Facts
- Concepcion denied any involvement in the snatching.
- He testified that they were riding the motorcycle when another motorcycle chased them, followed by an accident caused by a taxi bumping their vehicle, throwing Ogardo into a gutter.
- Police brought them to the hospital, and later a woman pointed him out as the snatcher; charges were filed the same day.
- Decisions Below
- The Regional Trial Court (RTC), Branch 81, Quezon City, found Concepcion guilty beyond reasonable doubt of robbery with homicide and sentenced him to reclusion perpetua, ordering reimbursement of P3,000 to Acampado.
- The Court of Appeals (CA), Fourth Division, affirmed the RTC decision in toto.
Issues:
- Whether the RTC and CA erred in giving weight and credence to the allegedly inconsistent testimonies of the prosecution witnesses.
- Whether the prosecution sufficiently proved Concepcion's guilt beyond reasonable doubt for robbery with homicide.
- Whether the snatching of Acampado’s shoulder bag constituted robbery or simple theft.
- Whether Concepcion can be held liable for the homicide of Ogardo which occurred during the incident.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)