Miyerkules, Agosto 30, 2017

PEOPLE vs. QUIÑONES (Case Digest)

PEOPLE vs. QUIÑONES
(183 SCRA 747)
March 28, 1990; G.R. No. 80042
Facts:
On June 30, 1986, the bodies of three men were found in a wooded area in barangay Tuaco, Basud, Camarines Norte. The corpses were in a state of decomposition and bore various contusions, stab and bullet wounds, and other injuries indicating foul play. The victims were later positively identified as Alexander Sy, Augusto Gabo and Frisco Marcellana.

In due time, an information for robbery with multiple homicide was filed against Adolfo Quiñones, Alfredo Aban, Zaldy Civico, Ronilo Canaba, Amado Conda, Jr., Santiago Solarte, Armando Buitre and one John Doe. 

The evidence for the prosecution established that the three victims were riding in a dark blue Mitsubishi car at about seven o'clock in the evening of June 27 or 28, 1986, when they were intercepted along the Maharlika Highway in the above-named barangay by the accused, who had placed sacks on the road to block the way. The three were taken to the nearby woods where they were killed.  According to his brother, Napoleon, Alexander Sy was at that time carrying P300,000.00, representing the weekly collections of his business, a necklace with pendant worth P20,000.00, a P10,000.00 diamond ring, and a licensed .22 caliber handgun.   All this, together with the other articles belonging to the victims, were taken by the accused, who also used the car in fleeing to Sapang Palay, where it was recovered without the stereo and the spare tire.

Issue:
Whether or not the accused are guilty of robbery with multiple homicide.

Held:

There is no crime of robbery with multiple homicide under the Revised Penal Code thus the charge should have been for robbery with homicide only regardless of the fact that three persons were killed in the commission of the robbery. In this special complex crime, the number of persons killed is immaterial and does not increase the penalty prescribed in Article 294 of the said Code.

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