FRANCISCO DE GUZMAN v. PEOPLE

FACTS:

The case involves a Petition for Review on Certiorari filed by petitioner Francisco de Guzman against the decision of the Court of Appeals (CA), which affirmed the decision of the Regional Trial Court (RTC) finding the petitioner guilty of the crime of robbery with force upon things. Private complainant Lucia Valdez and her husband Agustin Valdez separated, with Agustin going to the United States and Lucia staying in their house in La Union. After an earthquake in 1990, Lucia temporarily moved to an apartment in another town. Agustin asked his son Ramon Valdez to retrieve their personal properties from Lucia's house as she was allegedly selling them. Ramon, with the assistance of Marlon Gatchalian, Elpidio Picazo, and petitioner Francisco de Guzman, demolished a portion of Lucia's kitchen and brought out various personal belongings. Lucia's common-law husband, Agustin Mendegoria witnessed the incident and reported it to Lucia. Lucia later discovered that her belongings were brought to Ramon's house, except for a bench left outside petitioner's house. Lucia reported the matter to the police, and both Ramon and petitioner were charged with robbery with force upon things. Ramon admitted taking the properties but denied intending to gain from his act. Petitioner denied taking the properties for gain, claiming he was merely helping Ramon. The RTC found petitioner guilty, while Ramon was acquitted and directed to repair the wall he destroyed or pay the cost of repairs.

ISSUES:

  1. Whether or not petitioner Francisco de Guzman is guilty of the crime of robbery with force upon things.

  2. Whether or not the personal properties taken by the petitioner belonged to Lucia Valdez or to Ramon Valdez' parents.

RULING:

  1. The Supreme Court, affirming the decision of the Court of Appeals, held that petitioner Francisco de Guzman is guilty of the crime of robbery with force upon things. The Court found that the evidence sufficiently established that petitioner, along with Ramon Valdez and others, unlawfully entered the house of Lucia Valdez, took and carried away personal properties without the consent of the owner. The Court found no merit in petitioner's defense that he merely helped Ramon bring out the properties belonging to the latter's father. The Court also rejected the claim that the properties taken actually belonged to Ramon's parents and not to Lucia Valdez.

PRINCIPLES:

  • Robbery with force upon things is committed when, in the course of committing robbery, the offender employs violence or intimidation against any person or uses force upon anything. (Article 299, Revised Penal Code)

  • Ownership of the property taken is not an essential element of the crime of robbery. What is important is the unlawful taking and carrying away of personal properties without the consent of the owner.