Case Digest (G.R. No. 233104)
Facts:
People of the Philippines v. Eddie Manansala y Alfaro, G.R. No. 233104, September 02, 2020, the Supreme Court Second Division, Hernando, J., writing for the Court.
The accused-appellant is Eddie Manansala y Alfaro (Manansala); the prosecution is the People of the Philippines. Manansala was charged by Information with Murder for the November 2, 2013 killing of Armando Ramos, allegedly committed with treachery and evident premeditation. At arraignment he pleaded not guilty; pre-trial and trial followed in the Regional Trial Court (RTC), Branch 25, Manila.
At trial the prosecution presented eyewitnesses Edward Reyes and Renato R. Mananquil, the victim’s wife Corazon Ramos, the victim’s son Asas Ramos, Barangay Kagawad Jume Piojo, Police Officer 1 Leopoldo N. Tuazon, medico-legal expert Dr. Romeo T. Salen, and Senior Police Officer 1 Jonathan L. Moreno as investigating officer. The prosecution also introduced closed-circuit television (CCTV) footage and prints purporting to show a man identified as Manansala entering the victim’s house armed, shooting the victim on the stairs, then leaving. The medical testimony established a gunshot wound entering the victim’s back (lumbar region) with an upward trajectory, fatally lacerating the lungs and heart; the distance between muzzle and victim was about two feet or more.
Manansala testified in his defense, asserting an alibi that he went to Bulacan that evening and denying ownership of a firearm; his daughter Kiera corroborated his account. The prosecution adduced evidence of prior complaints and an earlier altercation between Manansala and the victim stemming from alleged illegal electrical jumpers the day before the homicide.
The RTC, in an October 20, 2015 Decision, convicted Manansala of Murder and sentenced him to reclusion perpetua, awarding civil and moral damages (the RTC’s full dispositive portion appears in the record). The RTC gave weight to eyewitness accounts and the CCTV footage, and found treachery and evident premeditation. The Court of Appeals (CA), in a January 5, 2017 Decision (CA-G.R. CR HC No. 07893), affirmed the conviction, upheld admission and authentication of the CCTV evidence (finding Asas competent to...(Subscriber-Only)
Issues:
- Was the evidence sufficient to prove beyond reasonable doubt that Eddie Manansala was the perpetrator of the killing?
- Were the qualifying circumstances of treachery and evident premeditation...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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