Case Digest (G.R. No. 238341)
Facts:
People of the Philippines v. Michael Torres y Natividad, G.R. No. 238341, July 14, 2021, Supreme Court First Division, Caguioa, J., writing for the Court. The appeal challenges the Court of Appeals (CA) Decision in CA‑G.R. CR‑HC No. 08841 (Oct. 26, 2017), which affirmed the Regional Trial Court (RTC), Branch 216, Quezon City, conviction for Robbery with Homicide in Criminal Case No. GL‑Q‑13‑181437.An Information was filed on April 3, 2013, charging Michael Torres with Robbery with Homicide under Article 294(1) of the Revised Penal Code. Torres pleaded not guilty at arraignment. The prosecution moved to amend the Information to clarify that the victim, Ramon Mallari, Jr., was shot first and thereafter robbed; the defense opposed as prejudicial. The RTC granted the motion on July 31, 2013, holding the amendment was not substantial and did not affect Torres’s substantial rights. An Amended Information dated August 12, 2013 was filed and trial ensued.
At trial the prosecution presented two eyewitnesses, Ace Obeda and Tobias Felices, who testified they saw Torres dismount a motorcycle, shoot Mallari in the chest, seize the victim’s gold necklace and bracelet, then shoot him again; Mallari later died from multiple gunshot wounds. The witnesses assisted in preparing a composite/cartographic sketch and, a few days after the incident, were taken to Masambong Police Station and shown Torres out of a detention cell for identification (a show‑up). Torres denied involvement, offered an alibi that he was detained for a traffic/possession offense after being stopped the day after the killing, and claimed suspicious circumstances during his custody including being brought before unidentified men while detained.
The RTC found the eyewitnesses credible, convicted Torres of Robbery with Homicide and sentenced him to reclusion perpetua, ordering awards for civil indemnity, moral, exemplary, and actual damages (RTC Decision dated November 24, 2016)...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in finding Torres guilty beyond reasonable doubt of Robbery with Homicide?...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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