Practice question
A proved robbery with homicide results in the deaths of two victims by reason of the same robbery. Counsel proposes the separate composite name robbery with double homicide solely because there are two deaths. Which is correct?
- Every additional death creates an entirely new statutory name.
- Only one death can ever be considered.
- The offense automatically becomes an Article 48 compound crime.
- All civil consequences disappear after the first death.
- Homicide is used generically in robbery with homicide; multiple killings do not by themselves require inventing a different composite offense name.
Legal references
- People v Jugueta, G.R. No. 202124, April 5, 2016, en banc main decision, Article 48 and composite crimes: https://lawphil.net/judjuris/juri2016/apr2016/gr_202124_2016.html
- People v Esugon, G.R. No. 195244, June 22, 2015, main decision, robbery with homicide as composite crime: https://lawphil.net/judjuris/juri2015/jun2015/gr_195244_2015.html
- Revised Penal Code, Article 48 as amended, text and current two-branch rule reproduced in People v Reyes, G.R. No. 260030, May 19, 2025: https://lawphil.net/judjuris/juri2025/may2025/gr_260030_2025.html
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