70 PEOPLE v. WILLIAM PAGE
Is Page guilty of robbery only or robbery with homicide – Robbery with
G.R. No. L-37507 | 7 June 1977 | J. AQUINO | PINEDA
TOPIC: wrongful act done though not originally intended
DOCTRINE: (Court did not directly address topic. I will just share my takeaway.)
While Page had not originally intended to kill Veronica, and while Page may
not have actually engaged in the killing of Veronica, under Article 4, he is
criminally liable for all the results stemming from his originally planned unlawful
act of robbery.
ER: Page and friend Camposano (who died) conducted a holdup of a jeepney.
On such occasion, Veronica (one of the passengers) fell out and died. SC
acknowledged she either died because Camposano pushed her or because
she was fearing Camposano who was threatening. Page convicted of robbery
with homicide. Page appealed conviction, arguing that he had nothing to do
with the homicide. SC upheld conviction as there was conspiracy – hence Page
is also a principal in the killing of Veronica.
FACTS:
1) Facts according to Page’s confession:
a) Page and his friend Camposano rode a jeepney from Taft-Harrison
headed to Manila.
b) Page sat beside a male passenger (Scot - Hyatt hotel EE) near the
driver, while Camposano sat at the back near 2 female passengers
(Veronica Balacapo – eventual victim; and Cesarea Villaverde)
c) Page and Camposano then held up the driver and three passengers.
They took money and jewelry. From rear view mirror of jeepneuy,
Page saw Camposano dumping the two female passengers on Roxas
Blvd in front of Casa Marcos. They sped away. Camposano gave
Page a watch and woman’s ring as his share of the loot.
2) Scot (male passenger) gave a different version. Scot said that Page
pressed a knife at Scot’s neck and began the holdup. Camposano then
told women to bring out money and not to shout. In front of Casa Marcos,
one of the women jumped out. The other woman that remained shouted,
causing Camposano to kick her – she fell off jeepney. They sped away.
a) The woman who jumoed out was Veronica. She was brought to PGH,
but dead on arrival. The other woman Cesarea was brought to
Ospital ng Maynila; record unclear re: survival.
3) Camposano was killed in a police operation as he was caught
committing another crime. Page was arrested.
4) Page was convicted of robbery with homicide.
5) Page is now assailing his conviction, claiming he had nothing to do with
the killing of Veronica – that it was Camposano’s own doing.
ISSUE/S:
1.
homicide, due to conspiracy.
HELD/RULING;
 Camposano caused death as he either pushed Veronica, or caused
so much fear that she had tried to escape. The rule is that if a man
creates in another person's mind an immediate sense of danger,
which causes such person to try to escape, and, in so doing, the latter
injures himself, the man who creates such a state of mind is
responsible for the resulting injuries.
 Page liable due to conspiracy. Page should answer for all the
consequences of the conspiracy, including the homicide which was
intertwined with the robbery committed by his conspirator. The
homicide was committed on the occasion or by reason of the
robbery.
o Page and Campisano were boyhood friends who were
spending time together hours before the crime.
o Inside the jeepney, their actions were coordinated. Page took
front seat, Camposano took back seat. They left the jeepney
and fled for same direction.
o The fact that they were carrying deadly weapons reveal they
had agreed to commit robbery inside a jeepney.
o The behavior of Page and Camposano inside the jeepney
disclosed a synchronization of their actions, evincing a prior
concert and plan to commit robbery with violence against
and intimidation of persons.
 The rule is that where the conspirarcy to commit robbery was
conclusively shown by the concurrent and coordinate acts of the
accused, and homicide was committed as consequence, or on the
occasion, of the robbery, all of the accused are guilty of robo con
homicidio whether or not they actually participated in the killing.
o Generally, when robo con homicidio has been proven. all
those who had taken part in the robbery are guilty of the
special complex crime unless it appears that they
endeavored to prevent the homicide.
Side issue on EJ confession:
The confession is admissible, as there was no coercion. Confession was
corroborated by the evidence on the corpus delicti, as Scot’s testimony and
the neceropsy report prove the corpus delicti – the fact that robbery with
homicide was committed.