Can a person be convicted of robbery with homicide when the person killed is one of the robbers and the fatal shot was fired by a police officer?
Case Title: People of the Philippines v. Ronilee
Casabuena y Francisco and Kevin Formaran y Gilera
G.R. No.: 246580
Date: June 23, 2020
Facts of the Case:
On October 11, 2012, at around 6:00 a.m., Ciara Kristle V.
Abella, a jeepney passenger, was robbed by three individuals: Ronilee
Casabuena, Kevin Formaran, and Jimmy Arizala. The robbers, armed with guns and
bladed weapons, declared a hold-up and forcibly took the personal belongings of
all the passengers, including Abella’s cellphone and wallet, and fled the
scene.
As the robbers were leaving the jeepney, PO2 Ramilo De Pedro
and PO2 Michael Albania, who were on patrol, responded to the commotion. Upon
being approached by the police officers, the robbers scattered. PO2 De Pedro
managed to confront Jimmy Arizala. During the struggle for Arizala’s gun, PO2
De Pedro fired two shots, fatally hitting Arizala in the chest. The two
remaining robbers, Casabuena and Formaran, were arrested at the scene.
The prosecution presented witness testimonies that clearly
identified the accused as the robbers, supporting their involvement in the
crime. The defense, on the other hand, denied the accusations, claiming they
were mistakenly arrested while on their way to visit a relative.
The trial court found both Casabuena and Formaran guilty of
robbery with homicide under Article 294(1) of the Revised Penal Code and
sentenced them to reclusion perpetua. The Court of Appeals upheld the
conviction, ruling that conspiracy was proven and that the death of Arizala,
even though he was a co-conspirator and killed by the police, was sufficient to
classify the crime as robbery with homicide.
Primary Issue Before the Supreme Court: Should the
appellants be convicted of robbery with homicide when the person killed was one
of the robbers and the killing was done by a police officer, not the robbers?
Supreme Court's Ruling:
The Supreme Court upheld the conviction, ruling that all the
elements of robbery with homicide were present in the case. The Court
reiterated that in a crime of robbery with homicide, the law does not require
that the person killed be the victim of the robbery; the killing of any person,
even a co-conspirator, on the occasion of the robbery, suffices. Moreover, it
does not matter who caused the death, as long as it occurred by reason or on
occasion of the robbery.
The Court rejected the defense's argument that there was no
direct connection between the robbery and the killing, stating that the
conspiracy between the robbers extended to the acts committed during and after
the robbery. As such, even though Arizala was killed by a police officer, the
appellants were still liable for the special complex crime of robbery with
homicide.
Dispositive Portion:
The Supreme Court affirmed the Decision dated July
25, 2018, of the Court of Appeals. Ronilee Casabuena and Kevin Formaran were
found guilty of the crime of robbery with homicide and sentenced to reclusion
perpetua. Their appeal was dismissed.
Should the law impose criminal liability for the death of
a co-conspirator if it was caused by a third party, such as a police officer
during the apprehension of the criminals?
Doctrines Discussed:
- Robbery
with Homicide (Article 294(1) of the Revised Penal Code): The crime of
robbery with homicide is committed when a homicide occurs on the occasion
or by reason of the robbery, regardless of who is killed or who causes the
death. The law does not require that the person killed be the victim of
the robbery.
- Conspiracy
in Criminal Law: Once a conspiracy is proven, the act of one
conspirator is deemed the act of all. Thus, all conspirators are equally
liable for the crime, regardless of their individual roles in the
commission of the felony.
- Intent
to Gain (Animus Lucrandi): The intent to gain can be inferred from the
unlawful taking of another’s property. Proof of direct profit or benefit
from the crime is not necessary to establish this element.
- Consequence of Homicide in
Robbery: In robbery with homicide, it is immaterial whether the death
occurs before, during, or after the robbery. The critical element is that
the homicide happens "by reason or on occasion of the robbery."
Thus, even if the homicide is committed by a third party, such as a police
officer, and even if the victim is one of the robbers, the remaining
conspirators are still liable for the crime.
- Liability in Conspiracy: The doctrine of conspiracy
holds that all conspirators are responsible for the actions committed in
the course of the conspiracy. This includes acts committed by any of the
conspirators, even those beyond the original plan, if they arise directly
from the criminal endeavor. Hence, even though the appellants did not kill
anyone directly, they were held equally accountable for the death of their
co-conspirator.
Case Classification:
This case falls under Criminal Law, specifically addressing the
complex crime of robbery with homicide as defined under the Revised
Penal Code of the Philippines.
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🎓 Welcome, future lawyers
and fellow baristas! In this short yet substantial content, we will break down
one of the most discussed Supreme Court rulings in Criminal Law — a case
that challenges traditional notions of liability in complex crimes.
This educational video aims to help law students and bar
examinees recall key doctrines and principles from the landmark case People
of the Philippines v. Ronilee Casabuena y Francisco and Kevin Formaran y Gilera,
G.R. No. 246580, promulgated on June 23, 2020.
📚 CASE OVERVIEW 📚
Nature of the Case: Criminal Law – Robbery with
Homicide under Article 294(1), Revised Penal Code
Title: People of the Philippines vs. Ronilee Casabuena and Kevin
Formaran
G.R. No.: 246580
Date of Promulgation: June 23, 2020
Parties: The People of the Philippines (Plaintiff-Appellee) vs. Ronilee
Casabuena and Kevin Formaran (Accused-Appellants)
Brief Summary:
Casabuena and Formaran were convicted for the complex crime of robbery with
homicide after participating in a jeepney hold-up. Although it was a third
party — a police officer — who shot and killed their co-conspirator Jimmy
Arizala, the Supreme Court ruled that the appellants are still criminally
liable for the special complex crime.
Main Legal Issue:
Can a person be convicted of robbery with homicide when the person killed is
a fellow robber, and the killing is done by a police officer?
SC Ruling: YES. As long as a homicide is committed
on the occasion of the robbery, even if the victim is a co-robber,
and even if killed by a third party, all conspirators in the robbery are
liable for the complex crime of robbery with homicide.
❓ Should robbers be liable for
the death of a fellow conspirator if the killing was done by a police officer
during lawful apprehension? Comment your thoughts below!
📌 10 IMPORTANT DOCTRINES
FROM THE CASE 📌
(All directly based on the Supreme Court's ruling in G.R.
No. 246580, June 23, 2020)
- Homicide
Can Be Committed Against Anyone
➡ “It is irrelevant if the person killed is a co-robber; once a killing occurs on the occasion of the robbery, the crime is robbery with homicide.” (pp. 9–11) - Act
of One is Act of All in Conspiracy
➡ “In conspiracy, the act of one is the act of all.” (p. 13; citing People v. Lago) - Intent
to Gain is Presumed
➡ “Animus lucrandi is presumed from unlawful taking.” (p. 10; citing Buenamer) - Conspirators
are Equally Liable for Homicide
➡ “Even if only one killed, all conspirators in robbery are liable for the homicide unless they tried to prevent it.” (p. 8–9; citing People v. Ebet) - Killing
by Police Still Counts for Robbery with Homicide
➡ “It is immaterial if the killing was committed by a police officer.” (pp. 10–11) - Article
294(1) Does Not Distinguish Who Must Kill
➡ “The word ‘any’ in Article 294(1) includes even co-conspirators as victims.” (p. 10) - Robbery
with Homicide is a Special Complex Crime
➡ “It is treated as a single, indivisible felony with a special penalty.” (p. 21; citing People v. Escote Jr.) - Conspiracy
Inferred from Coordinated Acts
➡ “Unity of purpose and action may be inferred from how the crime was carried out.” (p. 13; citing People v. Francisco) - No
Need for All to Benefit from Robbery
➡ “Not all conspirators need to profit for them to be guilty.” (p. 9) - Literal
Meaning of Penal Laws Prevails
➡ “Where law does not distinguish, courts should not distinguish.” (p. 10; citing Justice Mario Lopez’s opinion)
⚠️ DISCLAIMER ⚠️
This video is for educational purposes only and aims
to assist students and bar reviewees in recalling important doctrines in
Criminal Law. We do not guarantee infallibility.
Made using premium AI tools for legal education and review.
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🎓 Welcome to this short legal
quizzer designed specifically for law students, bar takers, and Criminal Law
enthusiasts! In this session, we will focus on a pivotal case that has
shaped how Philippine jurisprudence interprets complex crimes involving robbery
and homicide.
This quiz is based on the Supreme Court
ruling in People of the Philippines v. Ronilee Casabuena y Francisco and
Kevin Formaran y Gilera, docketed as G.R. No. 246580, and promulgated
on June 23, 2020.
📚 CASE SNAPSHOT 📚
Nature of the Case:
Criminal Law – Special Complex Crime (Robbery with Homicide)
Title: People of the Philippines vs. Ronilee Casabuena and Kevin
Formaran
G.R. No.: 246580
Date of Promulgation: June 23, 2020
Parties: The People of the Philippines (Plaintiff-Appellee) vs. Ronilee
Casabuena and Kevin Formaran (Accused-Appellants)
Brief Summary:
The accused were convicted of the special complex crime of robbery with
homicide after participating in a jeepney hold-up. During their apprehension, a
police officer shot and killed one of their co-conspirators. The legal
controversy centered on whether the surviving conspirators could be held liable
for homicide, even though it was committed by a third party and not against a
victim of the robbery. The Supreme Court ruled in the affirmative, holding that
the occurrence of a killing "by reason or on occasion of the robbery"
is sufficient to sustain the charge, regardless of who the victim or killer is.
✅ The Answer Key will be revealed
at the end of the video, so stay tuned and test your knowledge!
🧠 10 EASY DIFFICULTY HOTS (Higher-Order
Thinking Skills) MULTIPLE CHOICE QUESTIONS 🧠
- Which
of the following best describes the Court's reason for convicting the
accused of robbery with homicide, even though a co-conspirator was the one
killed?
A. The accused physically committed the
killing.
B. The police officer was negligent.
C. The killing occurred by reason or on occasion of the robbery.
D. The accused had prior criminal records.
- In
determining the guilt of the accused, the Supreme Court primarily relied
on:
A. The police officer's lack of
coordination.
B. The accused’s confession.
C. The established conspiracy among the robbers.
D. The financial value of the stolen items.
- The
rule that "the act of one is the act of all" applies because:
A. The accused ran away from the crime
scene.
B. The accused planned to surrender after the robbery.
C. The crime was committed in a public place.
D. The robbers acted in concert during the commission of the crime.
- The
killing of the co-conspirator by the police officer was considered:
A. A separate case of police brutality.
B. Part of the single crime of robbery with homicide.
C. Justifiable homicide not linked to the robbery.
D. A basis for dismissing the robbery charge.
- The
accused argued that the killing should not result in their liability
because:
A. They were not carrying weapons.
B. The police officer had no warrant.
C. The killing was not connected to the robbery.
D. They were minors at the time of the incident.
- The
Supreme Court rejected the accused’s argument because:
A. The robbery was not proven.
B. The killing was accidental.
C. There was a direct connection between the robbery and the killing.
D. The officer was not punished.
- In
deciding the case, the Court emphasized the importance of:
A. The motive of the police officer.
B. The distance between the robbery and the shooting.
C. The presence of a conspiracy.
D. The value of the stolen property.
- Under
jurisprudence, robbery with homicide may still be committed even if:
A. The stolen items are recovered.
B. The killing happens after the robbery.
C. The police fail to file a report.
D. The robbery was not premeditated.
- What
is a key reason the Court held the accused liable for homicide?
A. The accused planned the murder.
B. The killing happened on the occasion of the robbery.
C. The victim was part of the police force.
D. The accused resisted arrest.
- The
case clarified that the victim of the killing in robbery with homicide can
be:
A. Only the person being robbed.
B. Only innocent bystanders.
C. Anyone, including the robbers themselves.
D. Only police officers during chase.
🎓 Stay curious. Stay sharp. See
you at the answer key section!
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