Facts:

The case involves Elmer Estrada, also known as "Baby," who was convicted of murder for the killing of Alexander Almendras, nicknamed "Sonny." The incident occurred on November 27, 1963, at approximately 11:00 PM outside the Insular Cafe located at the corner of Juan Luna and Martires Streets in Cebu City. Witnesses reported seeing a flash of gunfire directed at Almendras, who subsequently fell to the ground. Upon arrival, police officers found Almendras dead, having sustained a gunshot wound that penetrated his chest and caused significant internal damage.

The police were informed by Jorge Cordero, a bystander, that "Sonny was shot by Baby Estrada," prompting them to pursue the assailants. Estrada, along with co-accused Alberto Tejero and others, was charged with murder, which included allegations of conspiracy and evident premeditation. During the trial, both Estrada and Tejero pleaded not guilty, asserting an alibi. The trial court ultimatel...

Facts:

1. Incident Overview: On November 27, 1963, at around 11:00 PM, Alexander Almendras (nicknamed Sonny) was shot and killed outside the Insular Cafe in Cebu City. Witnesses saw a flash of gunfire from the direction of three men standing in front of Almendras, one of whom was identified as Elmer Estrada (nicknamed Baby). Almendras fell to the ground after multiple gunshots were fired.
2. Immediate Aftermath: Jorge Cordero, a friend of Almendras, witnessed the shooting and immediately informed the police that "Sonny was shot by Baby Estrada." The police arrived, found Almendras dead, and pursued the assailants, who fled in a taxi.
3. Autopsy Findings: Dr. Venerando Pilapil conducted an autopsy and found that Almendras died from a gunshot wound to the chest, which penetrated vital organs. The bullet was recovered from his body.
4. Prior Conflict: Months before the shooting, there was bad blood between Elmer Estrada and Almendras. On June 8, 1963, Almendras had stabbed Estrada, causing serious injuries that required hospitalization. Estrada did not file a complaint but reportedly sought revenge.
5. Defense of Alibi: Estrada and his co-accused, Alberto Tejero, pleaded not guilty and claimed alibi. They argued that they were not present at the scene of the crime.
6. Trial Court Decision: The trial court acquitted Tejero due to reasonable doubt but convicted Estrada of murder, sentencing him to an indeterminate prison term. The court found that the killing was attended by the qualifying circumstance of evident premeditation.
7. Appeal to the Court of Appeals: Estrada appealed, but the Court of Appeals found that the trial court erred in applying the Indeterminate Sentence Law and certified the case to the Supreme Court, recommending a penalty of reclusion perpetua.

Issue:

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Ruling:

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Ratio:

1. Credibility of Witnesses: The Court upheld the trial court's findings on witness credibility, emphasizing that the trial judge is in the best position to assess the demeanor and truthfulness of witnesses.
2. Evident Premeditation: The Court found that Estrada had ample time to reflect on his actions, given the prior conflict and his threats against Almendras. This justified the qualifying circumstance of evident premeditation.
3. Penalty for Murder: The Court clarified that the proper penalty for murder, absent mitigating or aggravating circumstances, is reclusion perpetua. The Indeterminate Sentence Law does not apply to crimes punishable by life imprisonment or death.
4. Res Gestae Rule: The Court affirmed the admissibility of spontaneous statements made by witnesses immediately after the shooting, as they were part of the res gestae and reflected the excitement of the moment.

Conclusion:

The Supreme Court modified the penalty imposed by the trial court, sentencing Elmer Estrada to reclusion perpetua and ordering him to indemnify the heirs of Alexander Almendras in the amount of P6,000.00. The judgment was affirmed in all other respects.