Case Digest (G.R. No. 108493)
Facts:
People of the Philippines v. Danilo Daniel y Ramos alias Boyet, G.R. No. 108493, September 15, 1994, the Supreme Court Second Division, Puno, J., writing for the Court. The accused is Danilo Daniel y Ramos, alias Boyet; the prosecution is the People of the Philippines. Ramos was charged with murder in the Regional Trial Court of Malabon, Branch 169, under an Information alleging that on May 25, 1982, in Malabon he willfully and feloniously stabbed one Edgardo de Guzman with evident premeditation and treachery.At trial the prosecution presented four witnesses: Joseph Ang y Sandoval, Teofilo de Guzman (victim’s father), Dr. Alberto M. Reyes, and Edgardo F. Lazaro. Joseph Ang testified that from about seven meters away he saw the victim buying a cigarette when the accused came from behind, kicked the victim and stabbed him in the back with a balisong, then fled with the bloodstained knife. The wounded victim was brought to Chinese General Hospital and operated on but later died of severe hemorrhage. Teofilo corroborated that his son related the incident and identified the assailant; receipts for medical and burial expenses were introduced.
The defense moved for dismissal by demurrer after the prosecution rested; the trial court denied the motion, the accused waived presenting evidence and submitted the case for decision. The trial court convicted Ramos of murder on October 28, 1992, sentenced him to reclusion perpetua, ordered indemnity of P50,000 and actual expenses of P15,382.40, and found flight (accused’s alleged eight-year absence and rearrest in Davao) indicative of guilty mind. Ramos appealed, arguing (1) inconsistencies in witness statements and insufficiency/circumstan...(Subscriber-Only)
Issues:
- Did inconsistencies in witness testimony and the character of the prosecution’s evidence require reversal of Ramos’s conviction for lack of proof beyond reasonable doubt?
- May the accused’s prolonged absence and delayed arrest be considered an indication of guilt suppor...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)