G.R. No. 222916 - Heirs of Spouses Ramirez vs. Abon

The case involves multiple charges against police officers who are accused of committing heinous crimes in Benguet, Philippines.
The accused-appellants include SPO1 Jose Flores y Salinas, PO3 Romeo Artienda y Galvez, PO3 Manuel Corpuz y Lacuata, PO1 Amado Merca y Lopez, and PO3 Edwin “Eden” Tubiera y Detabli. Another accused, Leonito Macapagal, was charged but eventually acquitted for insufficiency of evidence, and one unknown person remains at large.
The offenses charged were committed in four separate informations under four criminal cases:

In Criminal Case No. 92-CR-1358, the accused are alleged to have attacked Vivian Gonzales Diones, a married woman, inflicting fatal wounds and causing the death of her unborn child through deliberate and premeditated acts.
In Criminal Case No. 92-CR-1365, the accused are alleged to have attacked Laurita Diones Nitcha, inflicting wounds on vital parts of her body that produced immediate fatality.
In Criminal Case No. 92-CR-1366, the accused targeted Zenaida Diones Ragadi with premeditated intent, attacking her in a similar manner and causing her death.
In Criminal Case No. 92-CR-1407, the crime of frustrated murder was charged in connection with the attack on Myrna Diones y Nitcha, whose injuries (including being tied, handcuffed, and struck with a wooden club) nearly caused her death even as her companions were similarly abused.

On June 17, 1992, Myrna Diones, along with her sister and companions, journeyed from Pangasinan to San Fernando, La Union, initially for errands that soon shifted direction.
At a drugstore in San Fernando, Myrna encounters accused Edwin Tubiera, after which the group is intercepted by members of the police force.
The victims were forcibly detained at the Canaoay Police Substation where they were confined in a small cell.
The following morning, around 19 June 1992, the accused convoked a vehicular trip during which the victims were transported, identified, and subjected to abusive acts—including handcuffing, tying with ropes, and physical assault with a pointed piece of wood.

Myrna Diones, the lone survivor, provided a detailed account of the abduction, detention, and assault. Her testimony describes the sequence of events from boarding vehicles to being attacked and eventually rendered unconscious.
Physical evidence included recovered bodies showing signs of strangulation, stab wounds, and other injuries consistent with the victim accounts; items such as a tire, rope, and a piece of wood were found in the vehicle used in the commission of the crimes.
The recovery of multiple victims’ bodies near Naguilian Road, along with ancillary evidence (sandals, shoes), prompted further investigation by the local police and the Criminal Investigation Service (CIS).
Line-ups and photographic identifications were conducted under the supervision of high-ranking police officials, where Myrna positively identified the accused from a set of approximately 35 photographs.

Each accused-appellant presented detailed alibi testimonies regarding their whereabouts during the commission of the offenses.
Testimonies provided by co-accused and other corroborating witnesses (barangay officials, neighbors, and fellow police officers) were aimed at establishing that certain accused were at their respective posts or at home during the incident.
The defense raised issues regarding inconsistencies in Myrna Diones’ account as well as challenges to the identifications made by her father, Eusebio Diones, regarding the bodies of the victims.

The trial court rendered a decision on 2 July 1993, convicting the five accused-appellants in all four cases except for Leonito Macapagal who was acquitted for lack of evidence.
The sentences imposed were as follows:

For Murder with Unintentional Abortion, Murder, and Murder (separately in Criminal Cases Nos. 92-CR-1358, 92-CR-1365, 92-CR-1366), the penalty of reclusion perpetua was imposed on the convictable accused.
For Frustrated Murder in Criminal Case No. 92-CR-1407, an indeterminate sentence ranging from Ten (10) years of prision mayor as minimum to Seventeen (17) years and Four (4) months of reclusion temporal as maximum was imposed.

The trial court explicitly rejected any suggestion from the media or defense that the crimes involved rape, stating that none of the evidence or testimonies contained any mention of such an act.
The trial record, spanning nearly 1,200 pages and extensive testimonies, reflects heavy reliance on the credibility of victim identification and the circumstantial evidence presented.

Whether discrepancies and “minor inconsistencies” in Myrna Diones’ testimony affect her credibility as the primary witness.
The significance of her emotional state and the circumstances under which her identification was made (e.g., crying on the stand, possible memory lapses under traumatic stress).

The challenge raised regarding the identification of the dead victims by Eusebio Diones in spite of conditions such as advanced decomposition and alleged inconsistencies in his testimony.
Whether the identification conducted through line-ups and photo arrays, supervised by police officials, suffices to establish the connection between the bodies and the alleged crimes.

The defense contended that the alibi testimonies—supported by co-accused accounts and corroborative witnesses—should exculpate the accused.
Whether or not the alibi evidence, despite being presented with corroboration by some witnesses, is credible in the face of the victim’s direct identification of the accused at the locus criminis.

The issue of whether the trial court erred in giving full credence to the testimony and identifications made by a sixteen-year-old survivor against the alleged weaknesses pointed out by the defense.
The legal standard on evaluating inconsistencies in witness testimony in light of the trial court’s findings and demeanor observations during cross-examination.