Facts:

The case involves Raymund Ardonio as the petitioner and the People of the Philippines as the respondent. The events transpired on April 4, 1991, in the Municipality of Lemery, Province of Iloilo, Philippines, during a fiesta celebration where a dance was being held. At approximately 1:00 a.m., a violent altercation erupted outside the dancehall involving Emmanuel Balano and Allan Ardonio, who had previously quarreled inside the venue. Witnesses observed Raymund Ardonio, along with Lito Ardonio and Elmer Calubia, attacking Emmanuel. Raymund was specifically noted to have pulled Emmanuel aside and shot him, resulting in Emmanuel falling face down. Following the incident, the assailants fled the scene, while Adolfo Ardonio, the father of Raymund and Allan, was seen holding a firearm nearby.

Raymund Ardonio was subsequently charged with homicide. During the trial, he pleaded not guilty. The prosecution presented evidence, including eyewitness accounts from Liezl Vitala and Salv...

Facts:

The Criminal Incident and Information

• On or about April 4, 1991, in the Municipality of Lemery, Province of Iloilo, Philippines, an altercation culminated in the fatal shooting of Emmanuel Balano.
• The information charged Raymund Ardonio with Homicide, alleging that he, armed with a firearm of unknown caliber, attacked and shot Balano—with indications of treachery and the abuse of superior strength—though the trial court later ruled out these qualifying circumstances.
• The reading of the information highlighted that the accused used a firearm in a willful, unlawful, and felonious manner, resulting in the victim’s death.

Events Leading to the Killing

• During a fiesta celebration in Brgy. Northwest Zone, Lemery, residents held a dance, and an altercation was reported among attendees.
• On the dawn of April 4, 1991, a violent commotion occurred outside the dancehall. Initial physical exchanges, including an altercation between Emmanuel Balano and Allan Ardonio, escalated.
• It was observed that three persons—Lito Ardonio, Elmer Calubia, and Raymund Ardonio—were involved, with Raymund specifically seen pulling Emmanuel aside and discharging a firearm, causing Emmanuel's death.
• Additional on-scene actions included the hurried retreat of the involved parties and the presence of another family member, Adolfo Ardonio, who was seen with a long firearm.

Evidence Presented at Trial

• Prosecution Evidence
• Eyewitness testimonies, notably by Liezl Vitala and Salvador Castor, identified Raymund Ardonio as the perpetrator responsible for shooting Emmanuel Balano.
• The sequence of events was reconstructed to show that after an initial altercation, Raymund’s intervention with a firearm directly resulted in the fatal wound.
• The prosecution maintained that inconsistencies in the account of petitioner regarding the events were overshadowed by the eyewitness identifications and the physical evidence.
• Defense Version
• Raymund Ardonio admitted his presence at the dancehall and acknowledged an altercation inside between Emmanuel and his brother Allan.
• The defense narrative stated that upon learning of the shooting from bystanders, the accused fled to his grandfather’s residence.
• It was further contended that despite being present at the time his brother, Allan, was arrested, Raymund was not apprehended, and therefore, this anomaly should raise reasonable doubt regarding his guilt.

Trial Court’s Findings and Sentencing

• The trial court found Raymund Ardonio guilty beyond reasonable doubt of homicide.
• It considered the positive identification from the credible eyewitnesses, Liezl Vitala and Salvador Castor, as conclusive evidence of his participation in the shooting.
• Though the defense raised issues regarding his alibi and the anomalous arrest of his brother, these were rejected by the trial court.
• The court sentenced Raymund Ardonio to a prison term ranging from fourteen years, eight months, and one day to seventeen years and four months, along with monetary penalties for compensatory damages, funeral expenses, and the payment of costs.
• The trial court also ruled that his alibi defense failed in the face of strong eyewitness identification and evidence of his active participation in the crime.

The Appeal and the Grounds Raised by the Petitioner

• Raymund Ardonio filed a petition for review on certiorari challenging the conviction, arguing that there existed evidence raising reasonable doubt as to his guilt.
• The petitioner focused on the discrepancy where prosecution witness Salvador Castor’s testimony—reporting the incident to the police with the allegation that it was Raymund who caused Emmanuel’s death—was seemingly contradicted by the arrest of Allan Ardonio.
• He asserted that the failure of police to arrest him at the time of his brother’s apprehension should have raised evidentiary doubts about his actual involvement in the crime.
• The fundamental contention was that guilt must be proven beyond reasonable doubt and that any evidence favoring his innocence should lead to his acquittal.

Issue:

Whether the evidence presented at trial, including the eyewitness testimonies, was sufficient to prove Raymund Ardonio’s guilt beyond reasonable doubt.

• The petitioner argued that reasonable doubt existed based on the inconsistencies in witness testimonies regarding who was actually apprehended by the police.
• The defense questioned whether the non-arrest of the petitioner should have cast doubt on the prosecution’s case.

The proper evaluation of the credibility of the witnesses

• Whether the trial court erred in giving full credence to the testimonies of Liezl Vitala and Salvador Castor.
• Whether the alleged lack of corroboration regarding the arrest and location of the petitioner sufficiently undermines their credibility.

The effect of collateral and insignificant factual inconsistencies

• Whether the minor discrepancies in the testimonies are material enough to affect the criminal conviction.
• The legal principle that any evidence tending to favor innocence must resolve the doubt in favor of the accused.

The implication of the petitioner’s flight and his absence at the time of the arrest

• Whether the accused’s departure from the scene constitutes an indicium of guilt.
• How the police’s actions and the subsequent arrest of Allan Ardonio impact the overall narrative of the crime.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)