People Vs Mendoza

Facts:
That on May 1991, in San Juan Metro Manila. The Accused Romeo Mendoza and Jaime Rejali armed
with guns and knives, conspiring together with one alias jack whose identity and present location
remains unknown unlawfully and felonious take and rib divest one Glory Orepeo cash money through
force and violence. This was done while the victim was on a jeepney. To do this they feloniously
attacked and employed personal assault upon the passengers of said jeep, causing one to hit her head
with a gun and then kicking her out the jeep forcing her to fall and thus hit her head on the pavement
thereby inflicting mortal injuries which caused her death and Punched another in the face and hitting
her head with a gun.

It must be noted that these two other victims were sisters, Grace and Ramilyn Zulueta, the one who got
punched and hospitalized and the one who died respectively. The accused Mendoza was able to get
away from the scene of the crime but was later apprehended when he was recognized by Grace selling
ice cream. Rejali, who was his co-worker, was also identified.

They were convicted of a violation of PD 532 (Anti-Piracy and Anti-Highway Robbery Law of 1974)

Issue:
Whether or not the accused should be convicted of highway robbery with homicide punishable under
PD 532 or with homicide under ART 294 of the RPC?

Held:
Decision of Regional Trial Court of Pasig Metro Manila is modified and are instead found guilty of
special complex crime of robbery with homicide under ART 294 of the RPC.

Ratio:
Highway robbery or brigandage is defined by Section 2 of said decree as follows:
e. Highway Robbery/Brigandage. - The seizure of any person for ransom, extortion or other
unlawful purposes or the taking away of the property of another by means of violence against or
intimidation of person or force upon things or other unlawful means, committed by any person
on any Philippine highway.
In fine, the purpose of brigandage is inter alia, indiscriminate highway robbery. If the purpose is
only a particular robbery, the crime is only robbery, or robbery in band if there are at least four
armed participants.

Presidential Decree No. 532 punishes as highway robbery or brigandage only acts of robbery
perpetrated by outlaws indiscriminately against any person or persons on Philippine highways as
defined therein, and not acts of robbery committed against only a predetermined or particular victim,

To obtain conviction for highway robbery then the prosecution should have proven that the accused, in
that instant case, were organized for the purpose of committing robbery indiscriminately. There was an
absence of such proof. There was also no evidence of previous similar robberies by the accused to
show indiscriminate commission.
Statcon

It would be absurd to consider any unlawful taking committed on highways would be covered thereby.
It must be noted that the spirit or intent of the law should not be subordinated to the letter. Considering
the letter of an instrument goes merely skin deep into its meaning. We must avoid absurdities and
conflicts. We must also take into account the principle that all doubts are to be resolved liberally in
favor of the accused.

Thus what we must consider is whether or not the very purpose for which the law has been
promulgated has been transgressed. It is hard to consider how a single act of robbery would be in effect
capable of stunning economic and social progress of the people as to be considered the highest forms of
lawlessness condemned by the penal statutes of all countries. Said isolated act constituting highway
robbery or brigandage would be an exaggeration bordering on ridiculous.

Mendoza and Rejali should be liable instead for the special complex crime of robbery with homicide
under Art 294 of the RPC, robbery having been duly established beyond reasonable doubt and
homicide due to being the cause of Ramilyn Zulueta's death. Conspiracy was also duly proven through
their unity so they shall both be liable.