Case Digest (G.R. No. 127130)
Facts:
The People of the Philippines v. Ernesto Ebias, G.R. No. 127130, October 12, 2000, the Supreme Court En Banc, Mendoza, J., writing for the Court. The case reached the Court on automatic review because the Regional Trial Court imposed the death penalty.The prosecution charged Ernesto Ebias (accused-appellant) and a John Doe with the complex crime of murder with frustrated murder for the July 8, 1994 shooting of Tirso Narez (who died) and Ronaldo Narez (wounded) in Barangay Dambo, Pangil, Laguna. The information alleged qualifying circumstances of treachery, evident premeditation and abuse of superior strength. At trial Ebias pleaded not guilty. The prosecution relied principally on the testimony and affidavits of Ronaldo Narez, who initially (July 11, 1994 affidavit, Exhibit B) identified his assailant by the alias “Boy Marantal” and later (August 16, 1994 affidavit, Exhibit F) stated that he had identified the shooter as Ernesto Ebias after seeing him on August 15, 1994.
During trial Ronaldo repeatedly affirmed in open court that Ernesto Ebias and “Boy Marantal” were the same person, although he could not identify Ebias’s companion because the companion’s face was covered. The defense presented denial and an alibi: a witness, Isagani Maray, testified Ebias was working at a nearby citrus plantation and home eating lunch at the time of the shooting. The plantation was said to be about ten meters from the incident site.
On May 15, 1996, the Regional Trial Court, Branch 33, Siniloan, Laguna found Ebias guilty beyond reasonable doubt of the complex crime of “MURDER with FRUSTRATED MURDER,” qualified by treachery, and sentenced him to death; the court awarded damages to the victims’ heirs and Ronaldo. Ebias’s appeal to the Supreme Court followed by automatic review. While the case was pending, Ebias filed (Nov. 20, 1998) a motion for appointment of counsel de oficio for a death-row inmate, Leonardo Eliseo, who had written a letter confessing to the crime; that motion was denied April 27, 1999.
On February 3, 2000, Ebias moved for a new trial on the ground of newly-discovered evidence: an affidavit by Leonardo Eliseo (executed Dec. 4, 1999; sworn Dec. 14, 1999) wherein Eliseo confessed to the shooting and narrated planning and execution of the attack. The Solicitor General did not dispute the chronology of discovery but opposed relief on the ground that Eliseo’s confession could not ...(Pro-only)
Issues:
- Does Leonardo Eliseo’s affidavit confessing to the shootings constitute newly-discovered evidence warranting a new trial?
- If so, what remedy is appropriate: remand for reception of the new evidence, and should the judgment be vacated pending f...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)