G.R. No. L-33604-05 - People vs. Ruiz

Several accused—including Jesus G. Ruiz, Alfredo Guno, Jose Inutan, Melquiades Ruiz, Romeo Dumancas, Peter Doe, and John Doe—were charged in two criminal cases docketed as Criminal Case No. 3323 (murder) and Criminal Case No. 3324 (double frustrated murder).
The allegations stem from an incident that occurred on December 16, 1966, at Nasipit, Agusan, where the accused were implicated in shooting and killing Sgt. Alfredo A. Bito and wounding several police officers.
Prior amended informations set forth the details of the crimes, and later procedural developments resulted in the exclusion of certain accused who were either deceased or not afforded the benefits of investigation.

The initial altercation arose when Jesus G. Ruiz, a prominent labor union president (of VISLU), had an argument with Sgt. Alfredo Bito over the improper parking of a police jeep near the VISLU office.

During the confrontation, Ruiz used the term “abusador” and was challenged to a draw by Bito.
The exchange of words intensified the situation and prompted Ruiz to depart hurriedly in his green pick-up.

Shortly thereafter, Ruiz returned with accomplices—including Alfredo Guno, among others—and the group proceeded towards Talisay where the showdown unfolded.

On arrival, the accused dispersed, assumed different positions near the scene (e.g., near a dilapidated truck and the VISLU office), and prepared for the ensuing shoot-out.
A fierce exchange of gunfire erupted between the group and the police personnel (Lt. Amado Felias, Sgt. Bito, and Patrolmen such as Galve and Granada), with multiple shots being fired.
Testimonies and physical evidence indicate that Ruiz fired a shot that struck Sgt. Bito in the face and/or leg, while other members (including Guno) engaged concurrently in the assault.

Prosecution witnesses—such as Libertad Bito Ruiz (sister of the deceased) and Patrolman Granada—provided detailed accounts corroborating that Jesus G. Ruiz fired the fatal shot.

Libertad testified that she observed Ruiz approaching and firing at her younger brother with one distinct shot, later noting he kicked Bito’s injured body.
Patrolman Granada corroborated witnessing events, including the sequence of shots and the fatal shot directed at Sgt. Bito’s mouth.

Forensic evidence backed the testimony; the post-mortem report by Dr. Lydia San Pedro identified distinctive bullet wounds, including an oval wound below the nasal septum, consistent with a shot fired at close range (within 24 inches).
The accused’s testimonies differed markedly from the circumstantial evidence:

Jesus G. Ruiz claimed that his actions were reactive to an insult and that his movements afterward were driven by a desire to avoid further conflict.
Alfredo Guno’s testimony attempted to distance him from the direct application of the fatal force, contending that he only discharged fire to deter an impending confrontation.

Additional details include the involvement of a motor vehicle (a green pick-up used by the accused) and the sequence of movements that suggested premeditated grouping, even if the time lapse was short.

The trial court rendered a decision convicting Ruiz for homicide and frustrated homicide and Guno as co-principal despite only inflicting a leg injury on Sgt. Bito, holding them jointly liable under the doctrine of conspiracy.
The lower court’s decision detailed the various errors alleged by the defense, including:

The admissibility and inherent credibility of prosecution witnesses’ testimonies.
The existence of mitigating circumstances such as immediate vindication of a grave offense versus claims of voluntary surrender or drunkenness.
The alleged procedural irregularities and questions of judicial bias during the trial.

In the appellate review, the errors raised by both the counsel for Ruiz and Guno were meticulously addressed, with the court finding no merit in refuting the established credibility of key evidence.

Whether the lower court erred in giving credence to the prosecution’s evidence and witness testimonies—especially from witnesses having personal relationships with the victim or the accused.
Whether the direct evidence and forensic findings sufficiently establish that Jesus G. Ruiz fired the fatal shot at Sgt. Bito, given contradictory statements by the accused.
Whether the doctrine of conspiracy was properly applied in holding Alfredo Guno liable as a co-principal, despite his claim of being a mere chance passenger with minimal involvement.
Whether the court correctly evaluated the mitigating circumstances, including the claim of immediate vindication of a grave offense versus the allegations of voluntary surrender and drunkenness.
Whether the lower court’s handling and selective acceptance or rejection of parts of witness testimonies (including reliance on rulings against challenges from defense counsel) amounted to judicial bias.
Whether the sentencing imposed—specifically the indeterminate penalties with set minimum and maximum periods—is appropriate considering all the factors raised in the evidence and the legal arguments.