View full case

RAMON AMPARO Y IBAÑEZ v. PEOPLE

FACTS:

The case involves a robbery incident that occurred in Manila, Philippines. Ahmed Alcubar, Roberto Guarino, Juanito Salmeo, and Ramon Amparo were charged with robbery for conspiring and confederating with each other. On April 26, 2007, the accused armed with deadly bladed weapons boarded a passenger jeepney and declared a hold-up by poking their weapons at Raymond Ignacio. They robbed Ignacio of his Nokia 6680 worth P14,000. Ignacio testified that he saw Salmeo and Amparo place their knives on the jeepney bench when the police fired a warning shot. SPO3 Renato Perez witnessed the incident and arrested Alcubar. He recovered weapons from Guarino, Salmeo, and Amparo. The accused were later found guilty of robbery in band by the Regional Trial Court and sentenced to imprisonment. They appealed the decision to the Court of Appeals, but their appeal was dismissed. Amparo, one of the accused, filed a Motion for Reconsideration, which was also denied. Consequently, a Petition for Review was filed before the Supreme Court.

ISSUES:

  1. Whether or not there is sufficient evidence to establish Amparo's active participation in the commission of the robbery;

  2. Whether or not Amparo should be acquitted on the ground of lack of evidence.

RULING:

  1. Yes, there is sufficient evidence to establish Amparo's active participation in the commission of the robbery. The fact that Amparo was caught with a weapon during the robbery is sufficient to establish that he had a common unlawful purpose with the rest of the accused.

  2. No, Amparo should not be acquitted on the ground of lack of evidence. A conviction can be based on the positive identification of the perpetrators by the victim and the presence of evidence that establishes a common unlawful purpose among the accused.

PRINCIPLES:

  • Positive identification of the perpetrators by the victim is sufficient to establish their guilt beyond reasonable doubt.

  • Active participation in the commission of a crime can be established through the presence of evidence that establishes a common unlawful purpose among the accused.

  • A conviction can be based on circumstantial evidence if it is sufficient to prove the guilt of the accused beyond reasonable doubt.