People v. Salvilla

Summary

Four armed men robbed New Iloilo Lumber Yard, taking P20,000.00 and personal property, then detained the owner, his daughters, and an employee as hostages while demanding P100,000.00 ransom. Police negotiations resulted in P50,000.00 payment, but accused refused to surrender. A police assault caused serious injuries including leg amputation of one victim. The Supreme Court affirmed convictions for complex crime of robbery with serious physical injuries and serious illegal detention, rejecting appellant's arguments that the crime was merely attempted and that voluntary surrender should mitigate penalty. The Court distinguished this case from precedents where detention was merely incidental to robbery, finding here that detention was a necessary means to facilitate the crime, warranting the penalty of reclusion perpetua under Article 48's complex crime provisions.