Facts:
The case involves Bernardino Peralta y Morillo (Peralta) and Michael Ambas y Reyes (Ambas) charged with Robbery with Homicide. The incident occurred on May 23, 2007. Superintendent Joven Bocalbos y Canas was driving his Nissan Urvan for additional income when several passengers, posing as regular fares, announced a holdup. They robbed the passengers of their belongings and shot Bocalbos in the head, resulting in his death. Witness Norberto Olitan (Olitan), who was also a passenger, identified Peralta and Ambas as the assailants. Ambos took valuables from Olitan, while Peralta drove the van and shot Bocalbos.
The accused were arrested based on the descriptions provided by Olitan, and upon their identification during a police lineup. Both Peralta and Ambas pleaded not guilty. However, the RTC found both guilty, a decision affirmed upon appeal by the Court of Appeals (CA). Peralta appealed to the Supreme Court, arguing dubious identification under poor lighting conditions.
Issues:
1. Whether the identification of the accused by Olitan was reliable given the conditions—dim lighting and the time elapsed between the crime and identification.
2. Whether the prosecution proved the elements of Robbery with Homicide beyond reasonable doubt.
Court’s Decision:
The Supreme Court affirmed the judgments of the RTC and CA. It scrutinized the identification reliability and determined that Olitan had a sufficient vantage point to recognize Peralta and Ambas despite dim lighting inside the van. The Court accepted the effectiveness of ambient street lighting and interior lighting from passing vehicles as adequate for identification.
1. **Identification Reliability**:
Despite dim van lighting, the Court ruled that sufficient street and vehicle lighting enabled Olitan to identify the culprits accurately. It noted that the proximity of Olitan to the suspects during the holdup allowed him to have a clear view of their faces, thus making his identification credible.
2. **Proving Robbery with Homicide**:
The Supreme Court found all elements of Robbery with Homicide were proven:
– Personal property was taken with violence or intimidation.
– The property taken belonged to another.
– The taking was with the intent of gain (animo lucrandi).
– The homicide was committed on the occasion of the robbery.
Doctrine:
The case reiterated the doctrine that testimonies based on positive identification by a witness, particularly from a closely involved individual like Olitan, can decisively outweigh the defenses of alibi and mere denial. The Court reaffirmed the application of the elements of Robbery with Homicide under Article 294 of the Revised Penal Code.
Class Notes:
Key Elements of Robbery with Homicide:
1. Taking of personal property with violence or intimidation.
2. Belonging of the property to another.
3. Taking done with intent to gain.
4. Commission of homicide by reason or on occasion of the robbery.
Pertinent Statute:
– Article 294 of the Revised Penal Code: “[A]ny person guilty of robbery with the use of violence against or intimidation of any person shall suffer the penalty of reclusion perpetua to death when by reason or on the occasion of the robbery the crime of homicide shall have been committed.”
Historical Background:
The case occurred in 2007, a period notable for intensified law enforcement against crimes involving robbery and homicide in urban areas like Quezon City. The decision underscores judicial diligence in affirming severe penalties for Robbery with Homicide to deter such offenses, reflecting broader efforts to address criminal activities impacting community safety during that decade.
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