Case Summary (G.R. No. L-31594)
Facts of the Case
On October 22, 1968, Puno and Tenarife, who had been drinking together, planned a robbery inside a passenger jeepney. Puno confronted Enorasa with a dagger while Tenarife threatened the jeepney driver and robbed Oyong at gunpoint. Following the robbery, Tenarife shot Oyong, resulting in the latter's death. The trial court convicted Puno based on the evidence presented, including his handwritten extrajudicial confession.
Legal Theories of Liability
Puno contested the conviction primarily on the grounds that he did not conspire with Tenarife to commit robbery with homicide, asserting instead that he should be liable only for simple robbery. However, the trial court reasoned that the evidence indicated a conspiracy between Puno and Tenarife due to their coordinated actions during the robbery, satisfying the legal requirements for collective criminal liability under the Revised Penal Code.
Conspiracy and Liability
The court determined that Puno’s actions, performed in concert with Tenarife, established a conspiracy. The law stipulates that when a crime is committed in furtherance of the conspiracy, all conspirators are liable for the resultant consequences, including any homicides executed during the commission of the robbery. Hence, Puno’s liability extends to the homicide committed by Tenarife because that act was intimately related to their mutual endeavor to commit robbery.
Presence and Effect
Although Puno did not directly shoot Oyong, the court underscored that his presence and coordinated actions were critical in emboldening Tenarife to carry out the fatal attack. The law recognizes that the violence accompanying robbery is closely linked to the criminal act itself, and Puno's involvement in the planning and execution of the robbery meant he bore legal responsibility for Oyong's death.
Application of Penal Provisions
Article 294 of the Revised Penal Code, addressing robbery with violence or intimidation, was applicable to Puno's actions. The court found no mitigating or aggravating circumstances present
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Case Overview
- The case involves an appeal filed by Romeo Puno from the conviction of robbery with homicide by the Court of First Instance of Manila.
- The court sentenced Puno to reclusion perpetua and ordered him to indemnify the heirs of Agustin Oyong, amounting to P12,150, and to pay Magdalena Enorasa thirty pesos along with costs.
- The robbery occurred inside a passenger jeepney, implicating Puno and his companion, Pablo Tenarife.
Facts of the Case
- The incident transpired on October 22, 1968, beginning with a meeting between Puno and Tenarife in Quezon City, where they drank beer.
- They traveled to Manila North Harbor, boarded a passenger jeepney, and carried out the robbery.
- Puno threatened Enorasa with a dagger and robbed him of his wallet, while Tenarife threatened the jeepney driver and shot another passenger, Oyong, after robbing him.
- Oyong was shot in the neck and died shortly after the incident.
- Puno was identified by Enorasa as the perpetrator of the robbery and later confessed to the police.
Legal Contentions
- Puno contended that he did not conspire with Tenarife and argued that he should only be l