Case Summary (G.R. No. 208524)
Charges and Proceedings
Peralta and Ambas were charged under Article 294, paragraph 1 of the Revised Penal Code (RPC) for the crime of Robbery with Homicide. The incident involved armed robbery inside the victim's passenger van, which Bocalbos was driving while also transporting passengers. Following their arraignment, both accused pleaded not guilty.
Prosecution's Version
The prosecution's key witnesses included the victim's widow, Ma. Christina Bocalbos, an eyewitness named Norberto Olitan Jr., and a police officer, SPO3 Reynaldo Reyes. The testimonies revealed that on the night of the crime, Bocalbos was ordered at gunpoint to vacate the driver's seat, and was subsequently shot in the head by Peralta, leading to his death. Olitan testified that he recognized both accused during the robbery, asserting he had a very close encounter with Peralta while the latter took over the vehicle's steering wheel.
Defense's Position
The defense presented alibi witnesses, asserting both Peralta and Ambas were elsewhere at the time of the incident. Peralta claimed to be at his second wife's house, while Ambas maintained he was working as a taxi driver. Both defenses centered on denying the accusations made by the prosecution, suggesting that it was impossible for Olitan to identify them due to poor visibility inside the van during the robbery.
Ruling of the Regional Trial Court
On December 20, 2010, the RTC found both Peralta and Ambas guilty of Robbery with Homicide, sentencing them to reclusion perpetua. The court emphasized the credibility of Olitan’s identification of the accused and the sufficiency of evidence proving the elements required for conviction, including the robbery and subsequent homicide.
Ruling of the Court of Appeals
The Court of Appeals upheld the RTC's decision on November 28, 2012, dismissing the accused’s claims regarding insufficient evidence for identification and asserting that Olitan's proximity to the perpetrators during the crime provided ample opportunity for accurate identification. The appellate court confirmed that the refusal of the accused's alibis did not outweigh the eyewitness testimony.
Appellant’s Arguments
In his appeal, Peralta argued that the CA erred by not recognizing the alleged failure of the prosecution to establish his identity beyond a reasonable doubt. He contended that the limited visibility inside the van hindered Olitan's ability to accurately identify him and his co-accused.
Court's Analysis and Ruling
The Supreme Court reviewed the records and affirmed the CA's ruling, maintaining that the prosecution adequately established the requisite elements of the crime of Robbery with Homicide as outlined in the RPC. The Court also discussed the eyewitness testimony's reliability despite the poor lighting conditions, emphasizing the importance of the cir
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Case Overview
- This case involves an appeal from the November 28, 2012 Decision of the Court of Appeals (CA) affirming the December 20, 2010 Decision of Branch 95, Regional Trial Court (RTC) of Quezon City.
- The RTC found Bernardino Peralta y Morillo (Peralta) and Michael Ambas y Reyes (Ambas) guilty beyond reasonable doubt of the crime of Robbery with Homicide, as defined and penalized under Article 294, paragraph 1 of the Revised Penal Code (RPC).
- Both accused were sentenced to reclusion perpetua.
Facts of the Case
- On May 23, 2007, at approximately 8:30 p.m., Superintendent Joven Bocalbos y Canas (Bocalbos) was driving his passenger van when the robbery occurred.
- The accused approached and announced a holdup while armed, forcing Bocalbos to vacate the driver’s seat.
- Peralta took control of the van and shot Bocalbos in the head, leading to his death, while Ambas and others robbed the passengers.
- Norberto Olitan Jr. (Olitan), a passenger, witnessed the events and later identified Peralta and Ambas as the perpetrators.
Proceedings Before the RTC
- Peralta and Ambas pleaded not guilty during their arraignment, and no stipulations of facts were made during the pre-trial conference.
- The prosecution presented key witnesses including:
- Ma. Christina Bocalbos, the victim's widow.
- Norberto Olitan Jr., an eyewitness.
- SPO3 Reynaldo Reyes, a police officer involved in the investigat