G.R. No. 127130 - People vs. Ebias

On July 8, 1994, at around 12:00 noon in Barangay Dambo, Pangil, Laguna, the accused-appellant Ernesto Ebias, together with an unidentified companion, allegedly attacked Ronaldo Narez and his cousin Tirso Narez.
The attackers, conveniently armed with a homemade gauge 12 sulpak and a bolo, ambushed the victims with evident premeditation, treachery, and an abuse of superior strength.
During the assault, Tirso Narez sustained multiple gunshot wounds—particularly in the abdomen and right shoulder—which led to his death the following day, while Ronaldo Narez incurred a gunshot wound on the right leg and survived after receiving prompt medical assistance.

Accused-appellant Ebias was charged with the complex crime of murder with frustrated murder; the charges were based primarily on the testimony of eyewitness Ronaldo Narez.
Ronaldo Narez, in both his affidavit (Exhibit B) and his testimony, identified his assailant by the alias “Boy Marantal” and later equated this name with Ernesto Ebias.
During trial, despite the defense's alibi—that Ebias was at a citrus plantation near the incident spot and had been seen at lunch with family—the evidence presented by the prosecution was deemed straightforward and convincing.
The trial court rendered a decision on May 15, 1996, convicting Ebias beyond reasonable doubt of “Murder with Frustrated Murder” and sentencing him to death, imposing indemnification payments for damages to the victim’s heirs and Ronaldo Narez.

Accused-appellant filed motions on appeal, contending that the prosecution failed to comply with the accused’s constitutional rights during confrontations with eyewitnesses and relied solely on the testimony of a perjured witness.
He also argued that the trial court overlooked uncontroverted facts and admissions against interests that could mitigate his conviction.
In a subsequent development, on February 3, 2000, Ebias moved for a new trial based on the submission of newly discovered evidence—a confession by Leonardo Eliseo, another death row convict, which allegedly ascribed the crime to Eliseo.
Leonardo Eliseo’s affidavit, authenticated on December 4, 1999, detailed his participation in a shooting on June 20, 1994, and included a confession that he was responsible for shooting the victims, thereby introducing a potential exculpatory element.

Ronaldo Narez initially identified his assailant as “Boy Marantal,” a name he claimed to recognize but could not fully explain the source of, as his prior acquaintance with the accused was minimal or based on casual neighborhood familiarity.
Discrepancies arose as another witness, Santiago Narez, testified that the accused was known by a different nickname (“Estoy”).
The identification process involved a “show-up” where the accused was presented singly, thereby raising concerns about possible police influence or pressure on Ronaldo Narez’s identification.

Accused-appellant maintained that even with reasonable diligence, the alleged confession of Leonardo Eliseo could not have been discovered during the trial since he learned of it only while in confinement.
The Solicitor General argued that despite the presentation of this new evidence, it could not overturn the positive and unerring identification made by Ronaldo Narez.
The contention focused on whether the newly discovered evidence met the criteria for a new trial—namely, that it was discovered after trial, could not have been produced earlier with due diligence, was material and of such weight that it could change the outcome of the judgment.

Whether Leonardo Eliseo’s confession constitutes newly discovered evidence that satisfies the requisites for a new trial.

Was the evidence discovered after trial and outside the realm of what could have been discovered with reasonable diligence?
Is the evidence material and capable of substantially affecting the outcome of the case if admitted?

The reliability and probative value of the eyewitness identification used in convicting the accused.

Does the manner in which Ronaldo Narez identified the accused—particularly the “show-up” procedure—unduly compromise the credibility of his identification?
How do the discrepancies in alias identification (Boy Marantal versus other nicknames) impact the overall integrity of the eyewitness testimony?

Whether the trial court’s reliance on Ronaldo Narez’s testimony was appropriate in light of inconsistencies and the potential influence of police procedures during identification.