G.R. No. L-31594 - People vs. Puno y Ma

On the afternoon of October 22, 1968, Tenarife, a resident of the squatters’ area near Pier 14, Manila North Harbor, visited his friend Romeo Puno at his residence in Quezon City.
Both men, aged thirty and natives of Tarlac, agreed to drink beer before embarking on a plan to commit a robbery.
They traveled by bus from Quezon City to Divisoria Market in Manila and later went to Zaragosa Street, Tondo, for additional drinks.
Fortified by alcohol, they proceeded to the piers at Manila North Harbor, near Pier 4, where their plan began to take shape.

The duo boarded a passenger jeepney driven by Rogelio Castelo. There were four passengers on board: Agustin Oyong, Magdalena Enorasa, Marcos Espina, and Eugenio Gallo.
Seating arrangements placed Puno near Enorasa, while Tenarife sat between Oyong and Gallo.
Puno used an eight-inch dagger to intimidate Enorasa and extracted from him a wallet containing thirty pesos.
Simultaneously, Tenarife brandished a gun, ordering the driver to “Patayin ang ilaw at holdup ito” (Turn off the light and hold up the jeep).
Tenarife threatened to kill the driver, then pointed his gun at Oyong, from whom he extracted a wallet and an Olma watch valued at P150, before shooting Oyong on the neck.
After the violent act, both men fled the scene in the same jeepney and later boarded another jeepney, continuing their spree of extortion before separating.

During their escape, Puno was injured when the jeepney driven by Castelo ran over his left foot.
Castelo, while rushing the mortally wounded Oyong to Mary Johnston Hospital, encountered further gunfire as Tenarife fired at his vehicle.
Agustin Oyong was pronounced dead shortly after his arrival at the hospital, with the autopsy attributing his death to a through-and-through gunshot wound on the neck that had complex implications on vital structures.
At the hospital, in the presence of policemen, Enorasa identified Puno as the individual who threatened and robbed him with a dagger.
Meanwhile, Tenarife, who evaded arrest initially, later executed an extrajudicial confession in a hospital a week after the robbery.

Appellant Romeo Puno admitted to the act of robbing Enorasa by means of intimidation using a dagger.
He claimed that he acted under duress or irresistible force, asserting that he was compelled by Tenarife, who was armed with a gun, to comply with the robbery.
However, there was no evidence to support any claim of duress or intimidation against Puno, and his role was further implicated by his presence and coordinated actions with Tenarife.
The prosecution’s evidence, including Puno’s handwritten extrajudicial confession and the corroborative testimony from the witnesses, established that there was a conspiracy between Puno and Tenarife to commit a robbery inside the jeepney.

Whether Puno conspired with Tenarife in the planning and execution of the robbery that escalated to homicide.
Whether the coordinated actions between Puno and Tenarife in boarding the jeepney and committing the robbery, with both being armed, sufficiently established a conspiracy.

Whether Puno acted under an irresistible force or uncontrollable fear, thereby mitigating his liability to simple robbery only.
Whether the evidence was capable of limiting his criminal liability so as to exclude his complicity in the homicide, attributing his role solely to robbery.

Whether, given the established conspiracy, Puno could be held liable for all consequences of the joint criminal act, including the homicide committed by Tenarife.
Whether the trial court properly applied the doctrine that in crimes of robbery with homicide all participants are held jointly and severally liable for the resultant death.