Facts:

The case involves the People of the Philippines as the plaintiff-appellee against Pamfilo Quimson, also known as Noel Quimson, the accused-appellant. The events transpired on the evening of August 17, 1995, in Barangay Bagumbayan, Ligao, Albay. A group consisting of Romeo Matias, Sr., Crisaldo Guimba, Raul Rendor, Glenda Villareal, and Antonio Flores was traveling in a blue Toyota Tamaraw FX when they were ambushed and shot at by unidentified gunmen, including the accused. Antonio Flores and Raul Rendor managed to escape the vehicle despite being wounded and sought refuge at the home of Romeo Matias, Sr. There, they informed Isidra Matias, the wife of Romeo, that Pamfilo Quimson was one of their assailants. Rendor was later taken to the hospital, where he underwent surgery for his injuries but ultimately died on August 21, 1995, due to respiratory failure.

The police investigation revealed that the ambush resulted in the deaths of four individuals: Romeo Matias, Sr., Crisal...

Facts:

Incident Overview

• On August 17, 1995, Romeo Matias, Sr., Crisaldo Guimba, Raul Rendor, Glenda Villareal, and Antonio Flores were traveling in a blue Toyota Tamaraw FX along Colon St. in Barangay Bagumbayan, Ligao, Albay.
• They were ambushed by gunmen, resulting in multiple fatalities and injuries.

Immediate Aftermath

• Antonio Flores (the driver) and Raul Rendor managed to escape the vehicle and sought help at the house of Romeo Matias, Sr.
• Rendor and Flores informed Isidra Matias (Romeo’s wife) that Pamfilo Quimson and unidentified companions were the assailants.
• Rendor and Flores were taken to the Albay Provincial Hospital, where Rendor later died from his injuries.

Police Investigation

• SPO1 Penafiel, SPO3 Bea, and PO3 Borromeo were the first responders. They found the Tamaraw FX on the roadside and transported Glenda Villareal and Romeo Matias, Sr. to the hospital.
• SPO3 Iglesia secured the crime scene, recovered 39 empty bullet shells, and documented the scene.
• Major Arroyo of the PNP Crime Laboratory concluded that the vehicle was fired upon from the right side and the back.

Victims’ Injuries and Death

• Romeo Matias, Sr.: Died on the spot with 16 gunshot wounds, including a fatal skull fracture.
• Crisaldo Guimba: Died on the spot with 14 gunshot wounds, including a fatal skull fracture.
• Raul Rendor: Sustained gunshot wounds to vital organs and died on August 21, 1995, due to respiratory failure.
• Glenda Villareal: Died on August 18, 1995, but no medical evidence was presented.
• Antonio Flores: Survived but did not testify in court.

Accused’s Defense

• Pamfilo Quimson claimed alibi, stating he was in Macalaya, Castilla, Sorsogon, drinking with fellow soldiers at the time of the incident.
• He argued that Raul Rendor’s dying declaration was inadmissible and that the prosecution’s evidence was unreliable.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Dying Declaration: For a dying declaration to be admissible, the declarant must be under the consciousness of impending death, competent as a witness, and the declaration must concern the cause and circumstances of death. Rendor’s statement met these requirements, as his severe injuries and medical condition indicated he was aware of his impending death.
2. Res Gestae: Statements made immediately after a startling event, without opportunity for fabrication, are admissible as part of the res gestae. Rendor’s statements to Isidra Matias were made spontaneously and were therefore admissible.
3. Credibility of Evidence: The Court found the prosecution’s evidence credible, including Rendor’s identification of Quimson. The lack of precision in identifying the firearms used did not undermine the overall credibility of the evidence.
4. Alibi: Alibi is a weak defense and must be proven with clear and convincing evidence. Quimson failed to prove it was impossible for him to be at the crime scene, especially since he admitted to being near the camp on the night of the incident.

Damages

• Civil Indemnity: P50,000.00 to each victim’s heirs.
• Actual Damages: P110,000.00 to the heirs of Romeo Matias, Sr. (supported by receipts). No actual damages were awarded to the other heirs due to lack of evidence.
• Moral Damages: P50,000.00 to the heirs of Romeo Matias, Sr., Crisaldo Guimba, and Raul Rendor. No moral damages were awarded to Glenda Villareal’s heirs due to lack of evidence.

Conclusion:

The Supreme Court affirmed the trial court’s decision, finding Pamfilo Quimson guilty of four counts of murder and imposing the death penalty. The Court upheld the admissibility of Raul Rendor’s dying declaration and res gestae statements, rejected Quimson’s alibi, and awarded damages to the victims’ heirs.