Short answer. It falls under the same article as robbery by forced entry, through a different branch of it. Breaking open locked or sealed furniture inside the house, or carrying it away to be broken elsewhere, is listed as a circumstance that brings the robbery within the heavier provision.
What the law says
1. By the breaking of doors, wardrobes, chests, or any other kind of locked or sealed furniture or receptacle. 2. By taking such furniture or objects away to be broken or forced upon outside the place of the robbery.
Revised Penal Code, Article 299 — Robbery In An Inhabited House. Read the full provision →
The article has two branches and either one is enough
Art. 299 lists, first, the means by which offenders entered the house or building, and then, separately, circumstances attending the robbery itself: 1. By the breaking of doors, wardrobes, chests, or any other kind of locked or sealed furniture or receptacle. 2. By taking such furniture or objects away to be broken or forced upon outside the place of the robbery. The two branches are alternatives. A robbery qualifies if the offenders got in by one of the listed means, or if, however they got in, one of these circumstances attended what they did once inside.
Which is why a peaceful entry does not answer it
The practical consequence is important for anyone assuming an unforced door disposes of the matter. A person admitted as a guest, a worker let in to do a job, or someone who came in through a door standing open has entered by no listed means at all — and can still be within the article if a locked cabinet, a sealed box or a chest was then forced. The branch is about what was broken inside, not about how anybody came to be there. That is a common misreading, and it usually goes the wrong way for the person relying on it.
What has to be broken, and what it must have been
The words limiting this branch are locked or sealed. Furniture or a receptacle that was closed but not secured is not what the clause describes, so a drawer simply pulled open, or a box with a lid resting on it, is a different matter from a cabinet whose lock was forced. The second circumstance closes an obvious gap: taking the whole receptacle away to break it somewhere else counts, so removing a safe or a strongbox intact and opening it later does not escape the branch.
What the case will be decided on
Almost everything here is physical and photographable: the state of the lock, the damage to the furniture, where fragments lie, and what is missing from the receptacle as against what was left elsewhere in the room. It also matters who legitimately held keys and combinations, and whether anything was disturbed before the scene was recorded. Photograph the furniture before repairing or moving it, and preserve the damaged lock itself. If you have been accused in a matter of this sort, that same material is what your account will be tested against.
Related provisions
- Revised Penal Code, Article 299 — Robbery In An Inhabited House
- Revised Penal Code, Article 302 — Robbery In Uninhabited Or Private Building