手机是账户资金的载体，但独立于账户资金。不能将手机内的账户资金视为手机的价值或者手机的使用价值。抢劫手机并获取账户资金支付密码时，不代表已经实际获取了账户资金，不能认为构成抢劫财产性利益。类比抢劫信用卡并使用司法解释认定抢劫手机转移账户资金行为构成抢劫罪的观点，系对司法解释的错误理解和机械使用，不能成立。在抢劫手机并转移手机内微信零钱、支付宝余额的案件中，行为人只实施了一个暴力、胁迫等行为，但涉及两个取财对象。对于转移微信零钱、支付宝余额能否评价为抢劫罪，要结合抢劫罪中的手段行为和目的行为的客观关联性思考。传统的“两个当场”过于形式化，且会造成处罚漏洞。以压制被害人反抗取得财物为实质依据，提出的“两个当场扩大说”缺乏明确性。可从被害人视角，将抢劫罪的中间结果限定在被害人客观上丧失财产处分自由。从抢劫罪实行行为本身的危险性出发，用危险现实化理论解读抢劫罪手段行为和目的行为之间的因果关系，即行为人实施暴力、胁迫等行为时指向具体的财物，取得该财物才是暴力、胁迫等行为的危险现实化结果。抢劫手机离开现场后转移微信零钱、支付宝余额的案件主要有四种类型：第一，抢劫手机时无转移账户资金的故意，偶然获知密码转账。此时转账行为应单独评价，由于机器不能被骗、第三方支付平台账户不等同于信用卡账户，对转移账户资金的行为应认定为盗窃罪。第二，抢劫手机时无转移账户资金的故意，利用原先知道密码转账。对此，应基于临时起意取财是否需要施加新的暴力、胁迫才能构成抢劫“两分说”，结合转账时间、被害人有无被拘禁、约束等，对转账行为分别评价为抢劫罪、盗窃罪。第三，抢劫手机时有转移账户资金的故意，通过暴力获取密码转账。应将行为时被害人的年龄、所处位置、身体情况、所受威胁等作为判断资料，判断被害人能否恢复对账户资金的控制、支配，区分是否构成抢劫罪。第四，抢劫手机时有转移账户资金的故意，偶然获得密码转账。根据被害人是否被压制反抗、被害人有无发生实质变化、行为人的暴力行为与取财行为是否具有意思、行为连续性，对转账行为分别评价为抢劫罪、盗窃罪。

The mobile phone is the carrier of the account funds, but it is independent of the account funds. The account funds in the mobile phone cannot be regarded as the value of the mobile phone or the value in use of the mobile phone. When the mobile phone is robbed and the account fund payment password is obtained, it does not mean that the account funds have been actually obtained, and it cannot be considered that the property interests have been robbed. The analogy of using judicial interpretation about robbing credit card to determine the act of robbing mobile phone to transfer account funds constitutes robbery is based on the wrong understanding and mechanical use of judicial interpretation, and cannot be established.In the case of robbing the mobile phone and transferring the wechat change and Alipay balance in the mobile phone, the perpetrator only carried out one act of violence or coercion, but involving two property objects. Whether the transfer of wechat change and Alipay balance can be assessed as robbery should be considered in combination with the objective correlation between the means behavior and the purpose behavior in the crime of robbery. The traditional “two sites ” is too formal and will cause penalty loopholes. On the basis of suppressing the victim‘s resistance to obtain property, the theory of “expansion of two sites ” is lacking in clarity. From the perspective of the victim, the intermediate result of the crime of robbery can be limited to the victim‘s objective loss of freedom of property disposal. Starting from the danger of the act carried out by the crime of robbery itself, this paper interprets the causal relationship between the means act and the purpose act of the crime of robbery with the theory of danger realizability, that is, when the perpetrator carries out the acts of violence and coercion, he points to the specific property and obtains the property, which is the result of the dangerous realizability of the acts of violence and coercion.There are four types of cases in which mobile phone robbers transfer wechat change and Alipay balance after leaving the scene. First, there is no intention to transfer account funds when robbing mobile phones, and they accidentally learn the password transfer. At this time, the transfer behavior should be evaluated separately. Since the machine cannot be cheated and the account of the third-party payment platform is not equal to the credit card account, the behavior of transferring the account funds should be identified as theft. Second, he did not intentionally transfer the account funds when he robbed the mobile phone, and transferred the money using the previously known password. In this regard, the transfer behavior should be evaluated as the crime of robbery and theft respectively based on whether new violence or coercion is required to take money from the temporary intention to constitute the "two-point theory" of robbery, combined with the transfer time, whether the victim is detained or restrained, etc. Third, when robbing mobile phones, there is a deliberate transfer of account funds, through violence to obtain the password transfer. The victim‘s age, position, physical condition and threat at the time of the act should be taken as judgment data to judge whether the victim can recover the control and control of the account funds and distinguish whether the crime of robbery is constituted. Fourth, when robbing mobile phones, the purpose of transferring account funds, accidental access to password transfer. According to whether the victim is suppressed and resisted, whether the victim has substantive changes, whether the perpetrator‘s violent behavior and the behavior of taking money have meaning, and the behavior continuity, the transfer behavior is evaluated as robbery and theft respectively.