Separate Robbery Convictions for Each Victim In California

"Robbery is the felonious taking of personal property in the possession of another from his person or immediate presence, and against his will, accomplished by means of force or fear." ( 211.) It consists of larceny plus two aggravating circumstances: (1) when the property is taken from the person or presence of another; (2) when the taking is accomplished by the use of force or threatened force. (4 Wharton, Criminal Law (15th ed. 1996) Robbery, 454, pp. 2-3; 2 Witkin & Epstein, Cal. Criminal Law (2d ed. 1988) Crimes Against Property, 635, p. 715.) Since the central element of robbery is force or fear, a defendant may be convicted of a separate robbery for each victim of such force or fear, even if the victims are in joint possession of the property taken. (People v. Ramos (1982) 30 Cal. 3d 553, 587-589 [180 Cal. Rptr. 266, 639 P.2d 908], revd. on other grounds in California v. Ramos (1983) 463 U.S. 992 [103 S. Ct. 3446, 77 L. Ed. 2d 1171]; 2 Witkin & Epstein, Cal. Criminal Law, supra, Crimes Against Property, 640, p. 722.) This doctrine provides that when property properly belonging to different persons is taken at the same time and place, only one larceny will lie for the taking. (Ibid.) Of the jurisdictions that at one time held to the contrary, all but one have subsequently abandoned that position in favor of the single larceny doctrine. ( Id. at p. 1410, 2, 3.) It is a doctrine implicitly recognized in analogous holdings in this state.