Case Digest (G.R. No. L-10951)
Facts:
The case involves Gregorio Ramirez as the defendant and appellant, with the People of the Philippines acting as the plaintiff and appellee. The events transpired on the evening of April 29, 1955, in San Teodoro, Oriental Mindoro, during a public religious service held by the "Iglesia ni Cristo." The deceased, Crisanto Manalo, was among the spectators, attentively listening to the Minister's sermon from a distance of approximately thirty meters. Jose Evangelista, who was five meters away from Manalo, witnessed Ramirez approach Manalo from behind and stab him with a nine-inch double-edged dagger. Evangelista had attempted to warn Ramirez against the impending attack, mentioning Manalo’s inability to defend himself due to his physical condition. After stabbing Manalo, Ramirez attacked Evangelista, causing him to flee with two stab wounds to the chest. Manalo was immediately taken to the provincial hospital, where he succumbed to his injuries the following morning. An
Case Digest (G.R. No. L-10951)
Facts:
- Incident Overview
- On the evening of April 29, 1955, during a religious service conducted by Iglesia ni Cristo in the poblacion of San Teodoro, Oriental Mindoro, a violent altercation occurred.
- The deceased, Crisanto Manalo—a non-member attending the service—became the victim of a stabbing by appellant Gregorio Ramirez.
- The Stabbing Incident
- At approximately 8:30 p.m., as the Minister was preaching from a platform about thirty meters away, eyewitness Mariano Canovas observed Ramirez positioning himself behind Manalo.
- Ramirez suddenly stabbed Manalo on the back with a double-edged dagger (9 inches long), causing Manalo to stagger and fall.
- Prior to the attack, another spectator, Jose Evangelista—located about two meters from Manalo—warned Ramirez not to harm him, but the stab had already been inflicted.
- Subsequent Events and Additional Violence
- Following the initial stabbing, as Evangelista attempted to intercede by separating Ramirez from Manalo, Ramirez stabbed Evangelista twice in the chest, inflicting wounds that led to Evangelista being hospitalized for nine days.
- The incident was immediately acted upon: Manalo’s statement was taken down by the police, due to urgent intervention by Dr. Sulit, and Manalo was rushed to the hospital where he later died.
- Autopsy and Medical Findings
- Dr. Manuel R. Luna conducted the autopsy, which revealed a profound stab wound on the back of the deceased:
- The wound measured 2½ inches long and 4½ inches deep.
- It was directed inward and downward at the infra-scapular region, just below the left nipple, perforating and lacerating the left diaphragm, lower left lung, stomach, and intestines.
- These findings decisively linked the stab wound delivered by appellant to the cause of death.
- Defendant’s Version and Testimonies
- Gregorio Ramirez admitted to inflicting the stab wound but pleaded self-defense, contending that:
- Two episodes of “suffocating smokes” during the service prompted him to search for those responsible.
- Upon being approached by Evangelista—who allegedly accused himself of causing the smoke—and then physically assaulted by him and another man (referred to as Manikis), Ramirez claimed he acted to free himself.
- His version described a sequence where Evangelista and Manikis engaged him physically, leading him to stab first Evangelista and then the deceased.
- Conflicting testimonies were presented:
- Ramirez’s account differed significantly from those of his co-members in Iglesia ni Cristo, Elpidio Matanguihan and Dante Gutierrez.
- Their conflicting versions detailed variations in the number of times Ramirez fell during the altercation, the direction and manner of the dagger thrusts, and whether the deceased grabbed or embraced the defendant.
- Physical evidence, including the autopsy and the deceased’s characteristics (e.g., short, paralyzed arms and fingers), further undermined Ramirez’s version, particularly the claim that the deceased could have embraced or grabbed him during the scuffle.
- Contradictions and Credibility Issues
- The trial court noted the discrepancies:
- Ramirez’s version was described as “incredible” and not supported by the testimony of his own witnesses.
- The three conflicting accounts on crucial aspects of the altercation (e.g., number of blows, defensive maneuvers, and positioning) rendered the self-defense claim dubious.
- The physical impossibility of the deceased delivering a grasp or embrace, given his physical limitations, further discredited the defense’s narrative.
- Motive and Context
- Although the prosecution did not establish a motive, the defense’s own evidence indicated:
- The disturbing smokes during the service, which could have reasonably motivated a sect member like Ramirez to seek retribution.
- The fact that the deceased, being a non-member, was singled out as responsible for the nuisance.
- This self-supplied motive, however, did not justify the use of lethal force.
Issues:
- Self-Defense Claim
- Whether the act of stabbing committed by Gregorio Ramirez was justified as a measure of self-defense.
- Whether the sequence of events, as testified by the conflicting accounts, sufficiently supported the claim of acting in self-defense.
- Credibility and Contradictions of Testimonies
- The reliability of the defendant’s version versus the accounts of his co-members and other eyewitnesses.
- The extent to which the inconsistencies in the narrative undermined the self-defense plea.
- Assessment of Motive
- Whether the presence of a motive—derived from the disturbance caused by the smokes during the service—is sufficient to support or negate the self-defense argument.
- The importance of motive in a case where the guilty party is definitively identified.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)