Case Summary (G.R. No. 232390)
Antecedents
Ramil, along with two other individuals identified as John Doe and Peter Doe, was charged with murder under Article 248 of the Revised Penal Code. The charge stemmed from an incident that occurred on August 27, 2002, wherein Ramil and his companions allegedly shot, stabbed, and hacked the victim, Mario Canaria, resulting in his death. The Information was filed on December 18, 2002, and Ramil was arraigned on April 14, 2003, pleading not guilty.
Evidence Presented
The prosecution presented several witnesses, including family members of the victim, who recounted the events of the evening of the murder. Marvin and Angel testified that while Mario was at home preparing for a serenade, Ramil and others entered and initiated a violent attack. The witnesses identified Ramil, asserting that he was the one who indicated Mario as a target for his assailants. Evidence from an autopsy confirmed that death was caused by multiple stab and gunshot wounds.
Defense Testimony
Ramil's defense argued that he was not present at the crime scene during the incident. He testified about being involved in a drinking session several meters away at a different location and produced witnesses to corroborate his alibi. However, the testimonies of Marvin and Angel pointed towards Ramil's strong presence at the crime scene based on recognition by voice and sight.
Ruling of the Regional Trial Court
On August 1, 2014, the Regional Trial Court found Ramil guilty of murder, sentencing him to reclusion perpetua and imposing damages, including moral and civil indemnity. The court held that the evidence sufficiently established Ramil's involvement and the presence of treachery during the attack.
Court of Appeals Ruling
Ramil appealed but his appeal was dismissed due to procedural issues, including failure to file his appellant’s brief on time. Upon Ramil's motion for reconsideration being denied, he escalated the matter to the Supreme Court, which considered the substantive merits of his appeal.
Supreme Court's Evaluation
The Supreme Court acknowledged the procedural missteps in Ramil's appeal but emphasized the importance of justice, considering his personal liberty at stake. The Court reaffirmed that the prosecution adequately established the elements of murder, including Ramil's role in identifying the victim, which facilitated the attack. While the Court validated Ramil's identification by the witnesses, it distinguished between being a principal and being an accomplice based on the nature of his involvement.
Finding of Accomplice Liability
The Supreme Court concluded that Ramil's actions amounted only to that of an accomplice rather than a principal actor in the murder. His mere identification of Mario, without any further directive or active participation in the murder, was insufficient to classify him as a principal. Thus
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Background of the Case
- The appeal stems from the decision of the Regional Trial Court (RTC) in Criminal Case No. 03-1040, which convicted Ramil Antigua y Quila (Ramil) of murder.
- The RTC sentenced Ramil to reclusion perpetua and ordered him to pay various damages to the victim's heirs.
- The case was brought before the Court of Appeals (CA) after Ramil's appeal was dismissed for procedural reasons regarding the filing of his appellant's brief.
Antecedents
- Ramil, along with two other co-accused, was charged with murder under Article 248 of the Revised Penal Code (RPC) for the killing of Mario Canaria on August 27, 2002.
- The Information cited intent to kill, treachery, and evident premeditation as circumstances surrounding the offense.
- Ramil pleaded not guilty during arraignment on April 14, 2003.
Prosecution's Evidence
- Witnesses Marvin Canaria and Angel Canaria Jr., the victim's children, provided testimony regarding the events leading to their father's death.
- They described a scenario where Mario, having returned home with family after a drinking spree, was attacked by Ramil and two accomplices.
- Witnesses testified that Ramil was heard identifying Mario to his co-assailants, which led to the victim being shot multiple times and stabbed.
Defense
- Ramil presented an alibi, claiming he was drinking with friends and was asleep at the time of the incident.
- He argued that the prosecution's evidence was insuffic