Mangulabnan and others broke into the Pacson family home armed with a knife and gun to commit robbery. During the robbery, one of the intruders fired a gun upwards without knowing Vicente Pacson was hiding in the ceiling, hitting and killing him. The Court of First Instance found the defendants guilty of robbery with homicide. On appeal, the Supreme Court affirmed, finding that under Article 294 of the Revised Penal Code, robbery with homicide is committed when a homicide results from or occurs during the commission of a robbery, regardless of whether the death was intentional or accidental.
Mangulabnan and others broke into the Pacson family home armed with a knife and gun to commit robbery. During the robbery, one of the intruders fired a gun upwards without knowing Vicente Pacson was hiding in the ceiling, hitting and killing him. The Court of First Instance found the defendants guilty of robbery with homicide. On appeal, the Supreme Court affirmed, finding that under Article 294 of the Revised Penal Code, robbery with homicide is committed when a homicide results from or occurs during the commission of a robbery, regardless of whether the death was intentional or accidental.
Mangulabnan and others broke into the Pacson family home armed with a knife and gun to commit robbery. During the robbery, one of the intruders fired a gun upwards without knowing Vicente Pacson was hiding in the ceiling, hitting and killing him. The Court of First Instance found the defendants guilty of robbery with homicide. On appeal, the Supreme Court affirmed, finding that under Article 294 of the Revised Penal Code, robbery with homicide is committed when a homicide results from or occurs during the commission of a robbery, regardless of whether the death was intentional or accidental.
THE PEOPLE OP THE PHILIPPINES, plaintiff and appellee, vs.
AGUSTIN MANGULABNAN alias
GUINITA, DIONISIO SARMIENTO, ARCADIO BALMEO, PATRICIO GONZALES, FLORENTINO FLORES, CRISPIN ESTRELLA, FELIPE CALISON, PEDRO VILLAREAL, CLAUDIO REYES, "PETER DOE" and "JOHN DOE" defendants, AGUSTIN MANGULABNAN appellant. No. L-8919 September 28, 1956 Introduction: APPEAL from a judgment of the Court of First Instance of Nueva Ecija. Parties: Factual Background: At about 11pm, Mangulabnan et. al, armed with kitchen knife and gun, entered and broke through the dwelling of Pacson family to rob. In the course of the robbery, Monica del Mundo, a resident therein, ended up injured after being strucked by the butt of the gun on the face and after warding off a blow to protect a child. Then, one of the unidentified intruder fired his gun upwards not knowing that Vicente Pacson is hiding in the ceiling. He was hit by the slug that passed through and was killed. Legal Antecedents: CFI found the defendants guilty of robbery with homicide. Legal Issue/s and Discussion: W/N the crime committed is robbery with homicide. Yes. Art. 294, par. 1, of the Revised Penal Code provides, according to its English text, that the crime is robbery with homicide "when by reason or on occasion of the robbery the crime of homicide shall have been committed.", but this is a poor translation. The Spanish text of the same provision reads, as follows: "Cuando con motivo o con ocasion del robo resultare homicidio." Therefore, In order to determine the existence of the crime of robbery with homicide, it is enough that a homicide would result by reason or on the occasion of the robbery and it is immaterial that the death would supervene by mere accident provided that the homicide be produced by reason or on occasion of the robbery inasmuch as it is only the result obtained, without reference or distinction as to the circumstances, causes, modes or persons intervening in the commission of the crime, that has to be taken into consideration.