Case Digest (G.R. No. L-8684)
Facts:
The case in question involves Jeffrey Collamat (also known as "Ric-Ric"), Jimbo Saladaga, and Ronilo Rondina, who were charged with murder under G.R. No. 218200, decided by the Supreme Court of the Philippines on August 15, 2018. The incident took place on January 13, 2002, at approximately 6:30 p.m. in Sitio Simborio, Barangay Tayud, Municipality of Liloan, Cebu. According to the Information filed on May 10, 2002, the three accused allegedly conspired to kill Esmeralda Gelido. During an altercation that arose from a spilled drink earlier that afternoon at Analyn's Store, tensions escalated. Witness Benido Jumao-as observed the assault, recognizing that Collamat and Ronilo held the victim while Jimbo stabbed her multiple times with an ice pick. Following the attack, the prosecution detailed that Gelido died due to massive hemorrhage from puncture wounds. The Regional Trial Court (RTC) found Collamat guilty of murder in a judgment issued on July 3, 2012, lCase Digest (G.R. No. L-8684)
Facts:
- Background and Charging
- The case involves appellant Jeffrey Collamat a.k.a. “Ric-Ric,” along with co-accused Jimbo Saladaga and Ronilo Rondina.
- They were charged with the murder of Esmeralda Gelido based on an Information dated May 10, 2002.
- The offense is alleged to have occurred on January 13, 2002, at Sitio Simborio, Barangay Tayud, Municipality of Liloan, Cebu.
- Prosecution Narrative
- Incident at Analyn’s Videoke Store:
- At around 4:00 p.m., Benido Jumao-as and the victim were drinking at the store.
- An altercation erupted after a spilled beer incident involving appellant’s table.
- A fistfight broke out, which was later pacified by Ramon Judaya who intervened.
- The Murder Incident:
- At approximately 6:30 p.m., after leaving the store, Benido observed the victim being attacked on the national highway.
- The victim was seen being held by members of the accused group—with appellant on one side and Ronilo on the other—while an unidentified person restrained the victim’s feet.
- Jimbo Saladaga was observed by the eyewitness, Benido, to stab the victim with an ice pick.
- Medical and Forensic Findings:
- The autopsy performed by Dr. Jesus Cerna revealed five stab wounds.
- The immediate cause of death was massive hemorrhage, with multiple puncture wounds noted, particularly in the victim’s right chest and clavicular areas.
- Defense Narrative
- Appellant’s Denial:
- The appellant denied any participation in the killing of the victim.
- He testified that he and his companions were singing and drinking at Analyn’s Store (a videoke session) from around 3:00 p.m. to 7:00 p.m.
- He further asserted that he left the premises and later went to his cousin’s residence in Opao, Mandaue City, thus offering an alibi.
- Trial Court Proceedings
- The Regional Trial Court (RTC), Branch 28, Mandaue City, issued a Judgment on July 3, 2012.
- Appellant was found guilty beyond reasonable doubt of murder under Article 248 of the Revised Penal Code.
- The RTC gave full faith to Benido’s positive and detailed testimony which identified appellant as one of the perpetrators.
- The RTC also held that the killing was attended by treachery due to the manner in which the victim was attacked—depriving him of any chance to defend or retaliate.
- Sentencing and Damages:
- Appellant was sentenced to suffer the penalty of reclusion perpetua.
- In addition, he was ordered to pay the heirs of the victim moral damages of P50,000.00 and temperate damages of P25,000.00.
- Court of Appeals Proceedings
- The Court of Appeals (CA) rendered its Decision on December 12, 2014.
- The CA affirmed the RTC Judgment with modifications.
- It directed appellant to pay the heirs of the victim an additional P30,000.00 as exemplary damages.
- The CA emphasized the reliability and consistency of Benido’s eyewitness identification, noting that despite a three-hour interval between the drinking session and the stabbing, the identification of appellant was clear.
- The CA reiterated that the victim’s stabbing, executed in a manner that left no opportunity for defense or retaliation, clearly demonstrated the qualifying circumstance of treachery.
Issues:
- Issue on Identification
- Whether the identity of appellant as one of the perpetrators of the crime was proven beyond reasonable doubt.
- Centered on the credibility and consistency of eyewitness testimony, particularly that of Benido, who positively identified appellant.
- Issue on Treachery
- Whether the victim’s stabbing was attended by the qualifying circumstance of treachery.
- Focused on whether the manner of the attack (i.e., the use of means that left the victim no opportunity to defend himself) fulfills the legal criteria for treachery in the commission of murder.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)