CASE DIGEST : PEOPLE VS PERALTA GR 227022 GAERLAN

 

[ GR No. 227022, Sep 29, 2021 ]

PEOPLE v. CRIS PERALTA Y DE GUZMAN +

DECISION

FACTS : The case involves Cris Peralta y De Guzman’s appeal from his conviction for robbery with homicide under Article 294(1) of the Revised Penal Code, arising from a jeepney holdup at around 3:30 a.m. on December 23, 2004 along Pasig Boulevard, Pasig City, where Cris, co-accused Jayson Abila, and two others declared a holdup, robbed the passengers, and, on the occasion thereof, shot and stabbed Police Officer 3 Florencio Antolin, who later died from gunshot wounds. Eyewitnesses Francisco and Fernando Antolin, the victim’s sons and passengers in the jeepney, positively identified Cris as the one who shot their father, corroborated by medico-legal findings and police investigation, while Cris interposed a defense of denial and alibi, claiming illegal arrest and mistaken identification. The trial court gave full credence to the prosecution witnesses, rejected the alibi, and convicted Cris, sentencing him to reclusion perpetua and ordering payment of civil indemnity and damages; Jayson’s case was archived due to his being at large. On appeal, Cris argued inconsistencies in the witnesses’ testimonies and the improbability of identification due to lighting conditions, but the Court of Appeals held that the alleged inconsistencies were minor and immaterial, that the lighting was sufficient for identification, and that the eyewitness identification was clear and categorical, thus affirming the conviction for robbery with homicide beyond reasonable doubt.

ISSUE : WON the CA is correct

HELD : Robbery with homicide under Article 294(1) of the Revised Penal Code is a composite crime where the intent to rob precedes the killing, and homicide—used in its generic sense—is committed by reason or on the occasion of the robbery, regardless of the time, manner, or victim of the killing; intent to gain may be inferred from the violent taking of property, and proof of the exact value or presentation of the stolen items is unnecessary. In this case, it was conclusively established that on December 23, 2004, four assailants declared a jeepney holdup in Bagong Ilog, Pasig City, forcibly took valuables from the passengers, including the service firearm and personal effects of PO3 Florencio Antolin, and that during the robbery, Cris Peralta shot Antolin twice, causing his death, while the stab wounds inflicted by the other assailants were superficial and non-fatal. The testimonies of Antolin’s sons, Francisco and Fernando, corroborated by other passengers and medico-legal findings, proved all elements of robbery with homicide beyond reasonable doubt, with their identification of Cris deemed credible due to sufficient lighting, close proximity, unobstructed view, and prompt identification shortly after the crime. Alleged inconsistencies in minor details were held immaterial as they did not relate to the elements of the offense or the fatal shooting, while Cris’s defenses of denial and alibi failed for lack of corroboration and physical impossibility. Consequently, the Court affirmed Cris Peralta’s conviction for robbery with homicide and modified the damages awarded by increasing moral damages and granting exemplary damages in favor of the heirs of PO3 Antolin.