G.R. No. 148730 - People vs. Dela Cruz y Dacillo

On July 13, 1999, at approximately 1:15 AM, a passenger bus of the Chinese-Filipino Friendship Transport, Inc. (CFFTI) was plying its route in Quezon City.
The bus, with Plate No. PXS 898, was operated by driver Terry Edma and conductor Antonio Dormitorio, who had been at work since the previous afternoon.
Along the way on the Alabang–Monumento–Letre route, the bus picked up several passengers, including a group comprising the accused-appellants—Jose dela Cruz y Dacillo, James Salboro y Jorolan, Edwin "Butch" Gener y Catean, and Arnel San Pedro y Tacome—along with three unidentified individuals.
An off-duty police officer, SPO1 Joven Avida Ebona of the Western Police District, boarded the bus in plain clothes.

As the bus neared Riverside St., Barangay Camachile along Commonwealth Avenue, accused-appellant James Salboro produced a .38 cal. revolver and announced a holdup.
Accused-appellant Arnel San Pedro, also armed, ordered the conductor Dormitorio to surrender the fare collections amounting to ₱3,000.00 and a Seiko 5 wristwatch.
Accused-appellant Jose dela Cruz directed driver Edma to pull over and turn off the vehicle’s interior lights, later ordering him at gunpoint to part with ₱2,000.00.
Subsequently, with the assistance of Edwin "Butch" Gener, the group systematically relieved the remaining passengers of their money and valuables.
During the commotion, SPO1 Ebona, initially asleep, was roused by the disturbance and, upon realizing the danger, was fatally shot by the assailants; his body was later found soaked in blood with post-mortem findings attributing his death to gunshot wounds in the head and trunk.
The perpetrators fled on foot, taking with them the service firearm of the deceased police officer.

Shortly after the incident, driver Edma drove the bus to the nearby Litex Police Detachment to report the robbery-homicide.
A team of detectives from the CIDG subsequently invited Edma and Dormitorio to identify the suspects from a rogues’ gallery, during which they positively identified Jose dela Cruz, James Salboro, Arnel San Pedro, and later Edwin "Butch" Gener.
Following these identifications, the accused-appellants were arrested between July 15 and 16, 1999.

The accused-appellants raised defenses of denial and alibi, with each claiming to have been elsewhere during the crime—differing assertions included transferring household belongings, taking care of a sick spouse, or staying home due to illness.
Eyewitness testimony of driver Edma and conductor Dormitorio was critical; both witnesses provided consistent identification of the accused during both the CIDG investigation and in open court.
Forensic evidence, including the medico-legal report, corroborated the fatal injuries sustained by SPO1 Ebona.
The case was complicated by an earlier similar incident involving bus robbery with homicide on EDSA, suggesting an organized modus operandi by the accused-appellants.

Whether the testimonies of bus driver Edma and conductor Dormitorio are sufficiently reliable given potential issues such as lighting conditions and confusion during the incident.
The impact of alleged discrepancies and inaccuracies in the details of their identification on the overall credibility of the evidence.

Whether the accused-appellants’ respective alibi defenses, asserting they were in different locations at the time of the crime, can satisfactorily exclude the possibility of their presence at the locus criminis.
Whether the defense’s argument regarding the "afterthought" identification of one of the accused (Edwin "Butch" Gener) undermines the integrity of the witness testimony.

Whether all essential elements—taking of property with violence or intimidation, the victimhood of the property owner, the intent to gain, and the occurrence of homicide in the context of the robbery—have been established beyond reasonable doubt.
Whether the penalty imposed (reclusion perpetua, as modified from the death penalty) is consistent with the evidence and legal requirements.

Whether evidence of an earlier bus robbery with homicide, involving similar methods, can be admissible to establish the systematic nature of the accused-appellants' criminal enterprise.