Case Digest (G.R. No. L-33604-05)
Facts:
The People of the Philippines v. Jesus G. Ruiz and Alfredo Guno, G.R. Nos. L-33604-05, October 30, 1979, Supreme Court En Banc, Fernandez, J., writing for the Court.The prosecution charged Jesus G. Ruiz, Alfredo Guno, and several others with crimes arising from a nighttime shooting at Talisay, Nasipit, Agusan on December 16, 1966. Two informations were filed in the Court of First Instance of Agusan del Norte and Butuan City: Criminal Case No. 3323 (murder of Sgt. Alfredo A. Bito) and Criminal Case No. 3324 (double frustrated murder for the wounding of Lt. Amado A. Felias and Patrolman Leonardo G. Galve). The cases were tried jointly under amended informations; some originally charged persons were later excluded or died, and some counts were dismissed.
At trial the prosecution presented eyewitness testimony (notably Libertad Bito Ruiz and Patrolman Granada), medical/post-mortem evidence showing facial and leg gunshot wounds on the deceased Sgt. Bito (including a blackened nasal area indicating close-range fire), and testimony regarding a prior altercation earlier that evening between Ruiz and the policemen over a parked police jeep. The defense witnesses, including the accused, denied culpability or invoked alternate explanations, and raised issues of bias, inconsistent testimony, and claimed mitigating circumstances (voluntary surrender, drunkenness, vindication of a grave offense).
The trial court (Court of First Instance, Branch II) convicted Ruiz and Guno: in Criminal Case No. 3323 it found them guilty of murder and sentenced them to death; in Criminal Case No. 3324 it found them guilty of frustrated homicide and imposed prison terms and damages; one co-accuse...(Subscriber-Only)
Issues:
- Did the trial court commit reversible error or manifest bias warranting reversal?
- Was the evidence sufficient and credible to sustain the convictions of Jesus G. Ruiz and Alfredo Guno?
- Was there treachery, evident premeditation, abuse of superior strength or other qualifying circumstance making the killing of Sgt. Bito murder rather than homicide?
- Was there conspiracy between Ruiz and Guno such that each is criminally liable as co-principal for the death of Bito and the injuries to Felias and Galve?
- Which mitigating circumstances,...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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