G.R. No. 101335 - People vs. Robles

On 21 December 1995, Leo Latoja, a laborer, prepared to leave for work after bidding farewell to his wife Shirley, their one-year-old child, and his mother Estelita.
While on his way, Leo discovered he lacked fare money and sent a co-worker to fetch money from his house; his wife, arriving shortly afterward, failed to give him money because she forgot her purse.
Leo’s mother, Estelita, intervened by providing him with money after he requested it upon her arrival.

As Leo received assistance from his mother and proceeded on his journey, Estelita, having just taken a couple of steps away, was startled by a gunshot.
In that very moment, she witnessed Gerry Silva alias “Sitoy” accompanied by two armed men—later identified as Alexander Gulane y Oledan alias “Alex or Armando” and “Boy”—aiming a gun at Leo.
Despite Shirley’s attempt to support her husband, Leo was struck by gunshots. Estelita, reacting instinctively, tried to intervene by lunging toward “Sitoy” but was met with violence as he struck her on the head and pushed her aside.

Leo Latoja was repeatedly shot by the three assailants, sustaining multiple gunshot wounds; his body was found soaked in blood on the pavement.
Leo was rushed to Tondo General Hospital by his grief-stricken mother but was pronounced dead before arrival.
The medico-legal report, prepared by Dra. Rosaline Cosidon of the PNP Crime Laboratory Service, noted nine gunshot wounds and three abrasions, with hemorrhage being the declared cause of death.
Estelita promptly reported the incident to the police, creating a blotter report that initially described the suspects in vague terms—as “three unidentified malefactors armed with unknown firearms.”

An Information for murder was filed on 17 May 1996 against Gerry Silva and two “John Does,” which on 9 December 1996 was amended to specifically name Gerry “Sitoy” Silva, Alexander “Alex or Armando” Gulane y Oledan, and Gilbert “Boy” Araneta as the accused for the killing of Leo.
During trial, witness Estelita Latoja positively identified the accused as the perpetrators despite initial police records only using their aliases.
Accused-appellant Gerry Silva claimed that a prior personal grievance—stemming from a fight over a girl—might have motivated a grudge on the part of the Latoja family, but he denied involvement in the fatal shooting.
Accused Alexander Gulane contended that he was a victim of mistaken identity, asserting that he had just arrived from Catbalogan, Samar, and had never been to Manila before; he further claimed he was confused with his similarly resembling cousin, Armando Gulane.
The defense argued that the delayed and seemingly afterthought identification by Estelita, coupled with inconsistencies in the police blotter report, rendered her testimony too conjectural and unreliable.

The trial court, relying on Estelita’s positive identification and the surrounding circumstances, originally found the accused guilty of murder.
It reasoned that Leo was taken entirely by surprise—rendered unprepared for defense—and that the attack was committed with treachery, evident premeditation, and conspiracy.
The court inferred that the time of the attack (just after daybreak) indicated deliberation and planning on the part of the assailants.

Whether Estelita Latoja’s identification of the accused is reliable despite inconsistencies in the initial police blotter report and the delay in naming the assailants.
The impact of her emotional state and the traumatic circumstances on the clarity and precision of her testimony.

Whether the killing of Leo Latoja should be classified as murder or merely homicide.
Whether the circumstances of the attack—specifically, the suddenness of the assault—provide sufficient basis to find treachery or evident premeditation, aggravating the crime to murder.

The weight to be given to the defenses raised by the accused, particularly the claim of mistaken identity by Alexander Gulane and the denial of involvement by Gerry Silva.
Whether these defenses, in view of corroborative evidence (i.e., Estelita’s testimony), create reasonable doubt regarding their participation in the killing.

Whether the mere fact that the victim was attacked by three armed individuals, and the time of the assault, suffices to establish elements of treachery or premeditation.
The legal threshold that must be met, by clear and convincing evidence, to elevate a homicide charge to one of murder.