Commonwealth v. Rozplochi, 385 Pa. Super. 357, 561 A.2d 25 (Pa. Super.), cert. denied, 524 Pa. 619, 571 A.2d 381 (Pa. 1989), the Court upheld two robbery convictions arising from a taking at one business establishment.
During the robbery, two employees were threatened with a gun, although only one was required to empty the company's safe. Moreover, the robber never took personal property from either employee; the money that was taken belonged solely to the business.
Nevertheless, because two employees were threatened in the course of the theft from the business, and the court viewed robbery as a crime against the person, with the focus on the physical danger to each person, the court concluded that the defendant committed two robberies.
In support of that result, the court also found that both employees "had a protective concern for the property of [their employer]." 561 A.2d at 30.
Thus, the court determined that when "a defendant threatens to inflict serious bodily injury on two employees in order to effectuate a theft of property from their common employer, the defendant may be convicted of two counts of robbery." Id.