PEOPLE v. CESAR CONCEPCION Y BULANIO

FACTS:

In this criminal case, Cesar Concepcion is charged with robbery with homicide under Article 294 of the Revised Penal Code. It is alleged that on May 25, 2004, in Quezon City, Concepcion, together with his co-accused Rosendo Ogardo, Jr., conspired to rob Jennifer Acampado. Concepcion and Ogardo forcibly took Acampado's shoulder bag containing personal items and cash worth P3,000. While fleeing the scene, Ogardo lost control of the motorcycle they were riding on, resulting in his death. Concepcion was found guilty of robbery with homicide by the Regional Trial Court (RTC) and sentenced to reclusion perpetua. The Court of Appeals (CA) affirmed the decision of the RTC. Concepcion raised several issues in his appeal, including the alleged inconsistencies in the testimonies of the prosecution witnesses, the failure to prove his guilt beyond reasonable doubt, and the argument that he should only be held liable for simple theft.

ISSUES:

  1. Whether the court erred in giving weight and credence to the inconsistent testimonies of the prosecution witnesses.

  2. Whether the court erred in convicting the accused-appellant despite the prosecution's failure to prove his guilt beyond reasonable doubt.

RULING:

  1. The Supreme Court affirmed the decision of the Regional Trial Court and the Court of Appeals.

PRINCIPLES:

  • Robbery with homicide is committed when there is a direct relationship or intimate connection between the robbery and the killing, whether the killing be prior or subsequent to the robbery, or whether both crimes are committed at the same time. It is immaterial that death supervened by mere accident or that the victim of homicide was a person other than the victim of robbery or that two or more persons were killed. (CA ruling)

  • The court gives weight and credence to the testimonies of prosecution witnesses unless it finds clear inconsistencies or contradictions that affect their credibility. (Issue raised by accused)