G.R. No. 214593 - Santos vs. Santos

On June 28, 2006, the appellants, Rogelio Ramos and Marissa Intero-Ramos, were charged with murder under Article 248 of the Revised Penal Code for the killing of Ronald A. Abacco.
The charge stemmed from events that occurred on or about April 11, 2006, at approximately 7:00 p.m. in the Municipality of Sto. Tomas, Province of La Union.
The Information alleged that the accused, motivated by an intent to kill and aided by superior strength, attacked the victim with a bladed weapon, resulting in multiple fatal wounds and causing massive injuries.

Eight prosecution witnesses, including Dr. Arsenio Parazo, PO3 Aris De Guzman, and others, testified to the events.
Testimonies described that Rogelio, after throwing stones at his brother-in-law’s house, and following verbal challenges, opened the gate for Abacco who, unarmed, approached and engaged them.

As soon as the gate was opened, Rogelio allegedly hacked Abacco twice with a samurai sword.
With Abacco on the ground, the accused dragged him into their yard and banged his head against a wall.
Despite the victim’s pleas for mercy, Marissa allegedly hacked Abacco on his back with a bolo, prompting Rogelio to continue striking until Abacco died.

Dr. Parazo testified that Abacco died of hypovolemic shock secondary to multiple deep and fatal wounds.
The wounds, distributed over the head, neck, shoulders, forearms, and back, were so severe that they exposed bones and nearly transected the victim’s spinal cord.

The case was initially tried in the RTC of Agoo, La Union, Branch 32 in Criminal Case No. A‑5295.
The Regional Trial Court convicted both accused beyond reasonable doubt and sentenced them to reclusion perpetua, along with ordering the payment of civil indemnity and moral damages to Abacco’s heirs.

Rogelio invoked self-defense, asserting that his actions were in response to an unprovoked and aggressive attack by Abacco.
Marissa presented a defense of denial and alibi, claiming she was not present at the precise moment of the killing.

According to their account, Rogelio was initially in his house when Abacco began throwing stones and shouting.
It was claimed that after receiving a bolo strike on his right arm from Abacco, Rogelio retrieved his samurai sword in order to defend himself.
Marissa’s account maintained that she had gone to a nearby house (Barangay Kagawad Tavora’s) to seek assistance, thereby contending that her alibi precluded her participation in the killing.

The defense narrative conflicted with eyewitness testimonies that placed both accused at the scene.
The physical evidence (extent and location of wounds) raised serious doubts regarding the proportionality of the self-defense claim.

The Regional Trial Court (RTC) rejected the self-defense claim on two main grounds:

The element of unlawful aggression was unestablished, particularly since evidence showed Abacco was unarmed and approaching in a non-threatening manner.
The means employed by Rogelio were found to be grossly disproportionate to any alleged aggression.

The RTC convicted both respondents of murder and imposed reclusion perpetua along with orders for monetary damages.
The Court of Appeals (CA) affirmed the RTC decision with modifications, including additional exemplary damages, reiterating that the evidence did not support a claim of self-defense or a credible alibi for Marissa.

Whether the accused, particularly Rogelio, successfully established the justifying circumstance of self-defense, given the evidence of his admission to having killed the victim.
Whether Marissa’s defense of denial and alibi is tenable under the requirements that (a) she was at another location, and (b) it was physically impossible for her to have been at the crime scene.
Whether the manner of the killing—including the use of treachery and excessive force—qualifies the crime as murder rather than a lesser offense.
Whether the trial court erred in giving undue credence to the testimonies of the prosecution’s eyewitnesses in light of the alleged ulterior motives attributed to some of them.
Whether the penalties and damages imposed, including reclusion perpetua and the various monetary awards, are appropriate considering both the nature of the offense and the evidence presented.