G.R. No. 208524 - People vs. Peralta y Morillo

This is an appeal involving Bernardino Peralta y Morillo and Michael Ambas y Reyes, who were charged and later convicted for the crime of Robbery with Homicide under Article 294, paragraph 1 of the Revised Penal Code.
The case stemmed from the events on May 23, 2007, in Quezon City, where during an attempted robbery inside a passenger van, the victim, Supt. Joven Bocalbos y Canas, was fatally shot in the head.

On May 23, 2007, while Supt. Bocalbos was driving his Nissan Urban Van along Commonwealth Avenue near Dona Carmen Subdivision, several individuals posited themselves as passengers.
At gunpoint, they announced a hold-up, forcing Bocalbos to stop the vehicle near Fairview Market.
An armed assailant, later identified as Bernardino Peralta, took control of the van by coercing Bocalbos to move to the rear.
After executing a U-turn, Peralta used a firearm to shoot Bocalbos in the head, resulting in a mortal gunshot wound.

Alongside the shooting, the assailants robbed the van's passengers of their belongings, which included a cellphone, silver ring, sunglasses, cash, and other personal effects.
Michael Ambas was specifically implicated in seizing personal effects from one of the victims, Norberto Olitan Jr., an eyewitness present during the incident.

Testimonies were given by key witnesses: Ma. Christina Bocalbos (the victim's widow), Norberto Olitan Jr. (eyewitness and passenger), and SPO3 Reynaldo Reyes (CIDU police officer).
Olitan’s direct identification of Peralta and Ambas, corroborated by the physical proximity during the crime and subsequent identification procedures, formed the cornerstone of the prosecution’s evidence.
Supporting evidence included the autopsy report by Dr. Filemon Porciuncula, which confirmed that the gunshot wound to the head caused the victim’s death.
The investigation was aided by cartographic sketches based on witness descriptions, and a police line-up that further reinforced Olitan’s identification.

Both accused pleaded not guilty during arraignment and presented alibi testimonies.
Michael Ambas claimed he was on duty as a taxi driver, supported by records that he was working until later hours and had remedial engagements at his company garage.
Bernardino Peralta asserted that he was at his second wife’s residence in Barangay Silangan on the night of the incident and later ran errands, such as buying fruits at Balintawak market.
Both accused attempted to rely on their denials and alibi defenses to counter the eyewitness identification, arguing compromised visibility due to the lights being turned off inside the van.

At the pre-trial stage, no stipulation of facts or admissions was agreed upon by the prosecution and defense.
The Regional Trial Court (RTC) of Quezon City, Branch 95, found Peralta and Ambas guilty beyond reasonable doubt and sentenced them to reclusion perpetua, along with awarding various damages and indemnities.
The Court of Appeals (CA) affirmed the RTC decision on November 28, 2012, upholding the reliability of Olitan’s identification and dismissing the accuseds’ alibi defenses.

Whether the prosecution established beyond reasonable doubt all the essential elements of Robbery with Homicide.
Whether the eyewitness identification by Norberto Olitan was reliable and free from suggestiveness despite the low-light conditions inside the van.

To what extent could the mere denials and alibi claims of the accused overcome the positive identification made by an eyewitness who was in close proximity during the crime.
Whether the presence of ambient lighting (from street lights and passing vehicles) sufficed to enable a clear visual identification inside the van.

The determination of whether the awards for civil indemnity, moral damages, and exemplary damages were properly computed and justified under prevailing jurisprudence.
Consideration of whether modifications in the damage awards, as later ruled by the court, were necessary to conform to legal standards and prior cases.