Special complex crime of robbery with rape

 "Finally, for the crime of robbery with rape, THE LAW DOES NOT DISTINGUISH WHETHER THE RAPE WAS COMMITTED BEFORE, DURING, OR AFTER THE ROBBERY, but only that it punishes robbery that was accompanied by rape. THE FACTS DO NOT BEAR OUT THAT THE ROBBERY WAS A MERE AFTERTHOUGHT, considering that AAA testified that accused-appellant "took time to disable her and then got away with her personal belongings."47

In sum, the prosecution established accused-appellant's GUILT BEYOND REASONABLE DOUBT. He was correctly convicted of the SPECIAL COMPLEX CRIMES OF ROBBERY WITH RAPE UNDER ARTICLE 294 OF THE REVISED PENAL CODE.


PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. PIO SALEN, JR. Y SENA, ACCUSED-APPELLANT. G.R. No. 231013, January 29, 2020.