Facts:

• Pamfilo Quimson, also known as Noel Quimson, was convicted of multiple murder and frustrated murder by the Regional Trial Court in Ligao, Albay, on June 30, 1997.
• The incident occurred on August 17, 1995, when Quimson and unidentified accomplices ambushed a group in a blue Toyota Tamaraw FX on Colon St., Barangay Bagumbayan, Ligao, Albay.
• Victims included Romeo Matias, Sr., Crisaldo Guimba, Raul Rendor, and Glenda Villareal, all sustaining gunshot wounds.
• Survivors Antonio Flores and Raul Rendor sought refuge at Romeo Matias, Sr.'s home; Rendor later identified Quimson as one of the assailants before dying from his injuries on August 21, 1995.
• Police investigation revealed multiple gunshot wounds on the victims, indicating treachery and evident premeditation in the ambush.
• Quimson was charged on October 2, 1995, pleaded not guilty, and was ultimately found guilty, receiving the death penalty and monetary damages for the victims' heirs.

Issue:

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Ruling:

• The Supreme Court affirmed the trial court's decision.
• The admission of Rendor's dying declaration was deemed appropriate.
• The court found res gestae applicable.
• The prosecution's evidence was sufficient to uphold Quimson's conviction.
• The death...(Unlock)

Ratio:

• For a dying declaration to be admissible, it must meet specific criteria, including the declarant's awareness of impending death.
• Rendor's condition and statements indicated he was conscious of his mortality at the time of his declaration.
• Medical evidence supported the seriousness of Rendor's injuries, and his statement was made shortly after the attack, qualifying as res gesta...continue reading