G.R. No. 232390 - People vs. Antigua y Quila

The case involves an appeal by accused-appellant Ramil Antigua y Quila challenging the Court of Appeals’ dismissal of his appeal against the Regional Trial Court’s conviction for murder.
The RTC’s Judgment (August 7, 2014) and associated Resolution (September 18, 2014) convicted Ramil of murder, sentencing him to reclusion perpetua and imposing monetary penalties for moral damages, civil indemnity, and exemplary damages.
The CA dismissed Ramil’s appeal due to his failure to file the appellant’s brief within the reglementary period and due to his counsel’s deficiency in providing a current and complete address.

On August 27, 2002, at approximately 11:30 p.m., in Barangay Exciban, Labo, Camarines Norte, an incident occurred in which Mario Canaria was attacked and killed.
The crime involved the use of a firearm and bladed weapons, with multiple stab, hacking, and gunshot wounds inflicted on Mario, resulting in instantaneous death.
Ramil, along with two unidentified assailants, was implicated in the incident. His role primarily involved identifying the victim by uttering the words, "[h]indi yan, yung isa," thus directing the attack.

Plaintiff-Appellee’s witnesses, which included Marvin Canaria, Angel Canaria, Ana Marticio, and Dolores de Claro, testified regarding the events leading to and during the incident.

Marvin and Angel testified that they heard Ramil’s identification of Mario based on his familiar voice.
Additional testimony highlighted that a flashlight from one of the assailants illuminated Ramil’s face, aiding in his identification.

Barangay officials’ accounts (from Brgy. Captain Lopez, Brgy. Kagawads Tenorio, Balmaceda, and Alim) corroborated aspects of the incident, despite inconsistencies regarding the clear presentation of Ramil by witnesses under dim lighting conditions.
Medical evidence provided by Dr. Marcelito B. Abas confirmed that the cause of death was “shock hemorrhagic due to multiple stab, hacking, and gunshot wounds” affecting vital organs.

Ramil testified that on the night in question he was involved in a drinking session with friends and later retired to his sister’s residence.
His alibi was supported by attempts to account for his whereabouts during the pertinent time, although the proximity of the residential areas (Brgy. Exciban and Brgy. Macogon) weakened his claim.
Ramil contended that his mere utterance of "[h]indi yan, yung isa" did not equate to an order or active participation in the killing, arguing that passive presence and ambiguous statements should not lead to a principal liability.

The RTC ruled that the evidence established beyond reasonable doubt that Ramil was the one who identified and indirectly aided the killing of Mario, thus rendering him guilty.
The court emphasized that his identification, confirmed by witnesses familiar with his voice and appearance, was sufficient to connect him to the crime.
The presence of treachery was noted based on the sudden attack on an unsuspecting victim, wherein the assailants, including Ramil, attacked without warning.
The RTC’s decision also dismissed Ramil’s alibi, holding that the geographical proximity of the barangays made it implausible that he could be elsewhere during the commission of the crime.

Whether the CA correctly dismissed Ramil’s appeal on the ground of failure to file his appellant’s brief within the prescribed reglementary period and the inadequacy of his counsel’s address for service.

Whether the evidence, particularly the identification by voice and visual cues, was sufficient to convict Ramil of murder.
Whether Ramil’s actions, limited to identifying the victim during the incident, establish his liability as a principal offender or merely as an accomplice under the provisions of the Revised Penal Code.