G.R. No. 232338 - People vs. Quillo y Esmani

Ramon Quillo y Esmani was charged with the crime of Murder under Article 248 of the Revised Penal Code.
The incident occurred on May 28, 2014, in Quezon City, Philippines, with the victim identified as Vivien Yap-De Castro.
The prosecution alleged that Ramon, with intent to kill, qualified by treachery and evident premeditation, shot Vivien twice on her head resulting in her death.

According to the Information, Ramon planned the commission of the crime and adopted a sudden and unexpected attack, ensuring that the victim would be caught unawares.
The details of the crime include the use of a motorcycle by a tandem, with the back rider (purportedly Ramon) allegedly shooting the victim while she was walking with companions.
Witness testimonies describe that the motorcycle stopped abruptly, the back rider shouted something to the victim, and fired two successive shots.
The medico-legal and autopsy reports confirmed that the fatal gunshot wound on her head was the immediate cause of death.

The prosecution presented several witnesses: Audrey Phoebe Yap-Lopez, Michael M. Marinas, Gina A. Besmonte, Corazon D. Dasig, and PO2 Jogene Hernandez.
Testimonies revealed that:

At about 6:30 p.m., while Vivien and her friends were walking along Ilang-Ilang Street, a black motorcycle approached them with two persons onboard.
The witnesses claimed to have seen the back rider’s face since he was not wearing a helmet, although later admissions by some witnesses indicated that only a shadow or partial features were noted.
The identification of Ramon as the back rider was made during a police line-up and subsequently in court.

Physical evidence included the photographic evidence and descriptions derived from the composite illustration prepared with assistance from witness Michael.

Ramon claimed that at the time of the incident he was in Water Hall, Barangay Payatas B, Quezon City, and later in Montalban where his first wife was hospitalized.
He offered an alibi corroborated by his movements prior to and after the shooting.
Ramon also testified to events on June 3–4, 2014, involving a separate altercation that led to his apprehension by police in Camp Karingal, describing physical abuse during his arrest.

The Regional Trial Court (RTC) rendered a judgment on June 29, 2015, finding Ramon guilty beyond reasonable doubt of murder and sentencing him to reclusion perpetua, along with monetary awards to the heirs of the victim (civil indemnity, moral, exemplary, and actual damages).
On appeal, the Court of Appeals (CA) upheld the conviction but modified the monetary award by imposing a legal interest rate of six percent per annum on the damages.
Ramon raised several issues on appeal disputing the positive identification by prosecution witnesses, the sufficiency of circumstantial evidence, and the presence of treachery.
The appellate and subsequent proceedings led to the Supreme Court re-examining the foundation of the conviction, focusing on the reliability of eyewitness identification.

Whether the prosecution witnesses were able to positively and reliably identify Ramon as the assailant.

The credibility and reliability of out-of-court identification (via police line-up) were heavily questioned.
The identification was based on attributes such as height and complexion, despite the witnesses acknowledging the inadequate viewing conditions (e.g., seeing only a shadow or having their attention focused on the weapon).

Whether the circumstances of the commission of the crime, particularly the alleged treachery, were established beyond reasonable doubt.

The issue of whether treachery was present is tied to the sequence of events where the assailant allegedly lingered after the crime, which is inconsistent with expected behavior in criminal acts.
The contradictory and dubious nature of verbal descriptions offered by the prosecution witnesses raised questions on this qualifying circumstance.

Whether the totality of circumstances test, as outlined in People v. Teehankee, Jr., was satisfied in using the out-of-court identification evidence as a basis for convicting Ramon.