Case Digest (G.R. No. 217426)
Facts:
On December 23, 2004, in Pasig City, four men including Cris Peralta y De Guzman allegedly held up a jeepney, robbed the passengers and shot and stabbed Police Officer 3 Florencio B. Antolin, who died of gunshot wounds; co-accused Jayson remained at large. Cris was arrested after identification by passengers and was charged on February 8, 2005; the Regional Trial Court convicted him of robbery with homicide under Article 294(1) of the Revised Penal Code and sentenced him to reclusion perpetua, and the Court of Appeals affirmed on March 2, 2016.
Issues:
- Was the identification of Cris Peralta y De Guzman proven beyond reasonable doubt to sustain a conviction for robbery with homicide?
- Do the alleged inconsistencies in the witnesses’ accounts and the accused’s alibi create reasonable doubt requiring acquittal?
Ruling:
The Supreme Court dismissed the appeal and AFFIRMED the convictions of Cris Peralta y De Guzman for robbery with homicide and the penalty of reclusion perpetua as affirmed by the Court of Appeals. The Court modified the monetary awards, increasing moral damages to P75,000 and adding exemplary damages of P75,000, and ordered payment of P72,000 (actual expenses), P4,430 (value of stolen items), P75,000 (civil indemnity), P75,000 (moral damages), and P75,000 (exemplary damages) with six percent interest per annum from finality.
Ratio:
The Court gave deference to the trial court’s and appellate court’s credibility findings because the case turned on eyewitness testimony and there was no showing that lower courts misappreciated material facts. The brothers Antolin had proximity, opportunity, and prompt identification within two days, and their testimony was corroborated by other passengers and the medico-legal report establishing death by gunshot; discrepancies related only to non-material details and the accused’s uncorroborated, inconsistent alibi did not raise reasonable doubt.
Doctrine:
- The elements of robbery with homicide are as set forth in Article 294(1) of the Revised Penal Code: forcible taking of personal property, ownership by another, intent to gain, and that homicide was committed on the occasion of or by reason of the robbery.
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