G.R. No. 98069 - People vs. Flores

Ramon Flores and Renato Macabiog were charged with the crime of Murder, with the information stating that on October 15, 1979, between 6:00 and 7:00 o’clock in the evening at Maglaoi Centro, Currimao, Ilocos Norte, the accused, acting in concert and with treachery and evident premeditation, attacked Camilo Mamuyac with a firearm.
As a result of multiple gunshot wounds, Camilo Mamuyac died instantaneously. The information further alleged aggravating circumstances such as the shooting being committed during nighttime, and provided a basis for the victims’ heirs to claim damages comprising actual, moral, and exemplary damages.

Both accused pleaded not guilty at arraignment. The prosecution presented six witnesses, including medical and eyewitness accounts, while the defense relied on the testimony of one witness, Soledad Flores, aside from the accused’s own statements.
On September 5, 1989, the trial court rendered its verdict:

Accused Ramon Flores was found guilty beyond reasonable doubt of Murder under Article 248 of the Revised Penal Code with treachery as an aggravating circumstance.
Flores was sentenced to reclusion temporal in its maximum period of seventeen (17) years, four (4) months, and one (1) day up to twenty (20) years, and was ordered to indemnify the victim’s heirs for thirty thousand pesos (P30,000.00).
Accused Renato Macabiog was acquitted for insufficiency of evidence.

Detailed eyewitness testimony of Evangeline Mamuyac, the victim’s widow, who described the sequence of events from the moment a gunshot was fired until she saw Ramon Flores face to face.
Testimony of Ernesto Mamuyac regarding a row between Camilo Mamuyac and Ramon Flores two weeks prior, during which Flores allegedly threatened to kill the victim.
Forensic evidence including an autopsy report by Dr. Florentino Carpio that described multiple gunshot wounds, the discovery of lead pieces in the body, and findings of extensive internal injuries.
Ballistic and chemical examination of the suspected firearm (a 12 gauge “Winchester” shotgun) submitted by the local police, which showed traces consistent with recent firing including soot and nitrates.

Soledad Flores, the mother of Ramon Flores, testified that on the night of the incident the accused was at home conversing with his siblings and only retired later, thus establishing an alibi.
Ramon Flores himself reinforced his mother’s account by asserting he was asleep when the arresting policemen came for him.
Flores explained his positive nitrate test result as being due to his engagement in spraying mango trees with potassium nitrate that afternoon.

The Court of Appeals, despite finding Flores guilty, increased his penalty to reclusion perpetua and elevated the civil indemnity to fifty thousand pesos (P50,000.00).
The appellate court cited Section 12 of Rule 124, mandating that when the penalty of death or life imprisonment, or its equivalent reclusion perpetua, is contemplated, the case must be certified to the Supreme Court for final determination.

Appellant Ramon Flores argued that the testimony of Evangeline Mamuyac was highly irregular and improbable, raising the following issues:

It was impossible for her to have seen the flare of the gunfire given her position behind her husband at the time of the shooting.
Her act of peering through the bamboo “batalan” immediately after the gunshot was deemed an unnatural reaction under such traumatic circumstances.
The delayed disclosure of the gunman’s identity was argued to cast doubt on the veracity and reliability of her testimony.
The defense also stressed that the detailed, yet uncorroborated, testimony should undermine the prosecution’s evidence.

Additionally, Flores faulted the trial court for placing undue emphasis on what he asserted were minor inconsistencies among the defense witnesses’ testimonies.

Whether the detailed yet uncorroborated testimony of Evangeline Mamuyac can be accepted as credible evidence despite the alleged irregularities in her account.
Whether the delay in identifying the perpetrator by the widow, as well as her actions immediately following the incident, should adversely affect her credibility.

Whether the testimony provided by Soledad Flores and the accused’s own statements establishing an alibi are sufficient to exonerate the accused from the crime.
The requirement for incontrovertible and consistent evidence establishing that the accused was in a different location at the time of the crime.

Whether the forensic evidence (including the autopsy findings, nitrate tests on the accused’s hands, and ballistic tests of the recovered firearm) sufficiently establishes a link between the accused and the crime.
The degree to which the inconsistencies in the defense witnesses’ testimonies impact the overall certainty of the accused’s presence at the scene.

Whether the cultural context and the typical observance of mourning rituals in the Philippines justify the delay in the widow’s sworn statement identifying the gunman.
The extent to which such delays are admissible without automatically detracting from the eyewitness’s reliability.