Case Digest (G.R. No. 65345-47)
Facts:
The People of the Philippines v. Hermenegildo Ramirez @ Mijer, Felipa Ramirez, Apolonio Bagispas, Carlito Maghinay and Cristito Ceferino, G.R. Nos. 65345-47, January 31, 1989, Supreme Court First Division, Cruz, J., writing for the Court.Five persons were originally charged in the Regional Trial Court (RTC) of Zamboanga del Norte with robbery in band with double homicide and frustrated homicide arising from the October 31, 1980 attack on Paterno Ramirez and members of his household. One accused remained at large (Cristito Ceferino). Apolonio Bagispas was discharged and testified for the prosecution as a state witness. Carlito Maghinay was convicted but did not appeal and has been serving his sentence. The remaining accused-appellants, Hermenegildo Ramirez and Felipa Ramirez, were convicted by the RTC as principals by inducement and appealed their convictions.
At trial the informations had originally charged robbery in band with double homicide and frustrated homicide, but were later amended after further investigation to charge homicide and frustrated homicide as the central offenses. The RTC, after considering testimony from Bagispas (the discharged witness), Maghinay, Daniel Vidal (a neighbor), police testimony (Sofronio Antiquina), and Esteban Alfaro (a son-in-law), found that the Ramirez spouses had instigated the killings despite not being present at the scene. The RTC relied on testimonies that the spouses had asked others to kill Paterno, longstanding enmity between brothers Hermenegildo and Paterno over property, and alleged admissions and conduct after the crime.
On appeal to the Supreme Court (this Court), the accused-appellants challenged the sufficiency and admissibility of the evidence, including extrajudicial confessions and the credibility of prosecution witnesses. The Court reviewed the record, found the extrajudicial confessions tainted by constitutional infirmity, questioned the reliability and imp...(Pro-only)
Issues:
- Are the extrajudicial confessions of prosecution witnesses admissible against the accused-appellants?
- Did the prosecution present sufficient and credible evidence to sustain the conviction of Hermenegildo and Felipa Ramirez as principal...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)