Case Summary (G.R. No. 203986)
Facts of the Case
On January 25, 2008, the Office of the City Prosecutor of Las PiAas filed a murder charge against Jerson DasmariAas and his co-accused Nino Polo, alleging that on June 16, 2007, in Las PiAas City, they shot and killed PO2 Marlon N. Anoya with treachery, abuse of superior strength, and evident premiditation. The prosecution presented several witnesses, including Aries Perias, who testified seeing DasmariAas shoot the victim. Defendants DasmariAas and Polo both pleaded not guilty during their arraignment.
Trial Proceedings
During the trial, the prosecution's key witness, Mr. Perias, recounted the sequence of events leading to Anoya's death, stating he identified DasmariAas as one of the assailants based on the proximity and lighting at the crime scene. Meanwhile, the defense, led by DasmariAas, argued that he had an alibi and denied any involvement in the murder, claiming that witnesses identified him under suggestive circumstances. The defense also called upon DasmariAas' live-in partner to validate his alibi.
Regional Trial Court’s Judgment
On January 10, 2011, the RTC found DasmariAas guilty of murder and sentenced him to reclusion perpetua, alongside significant monetary damages to be paid to the victim's heirs. However, Polo was acquitted due to the lack of sufficient evidence against him.
Court of Appeals Ruling
On May 28, 2012, the CA affirmed the RTC's ruling but modified the civil liability imposed on DasmariAas, including an increase in civil indemnity due to the established severity of the crime.
Legal Issues on Appeal
DasmariAas appealed, raising two primary issues: (1) that his out-of-court identification was flawed and improperly influenced by law enforcement procedure, thus violating his right to due process; and (2) that the prosecution failed to prove his guilt beyond a reasonable doubt.
Supreme Court Ruling
The Supreme Court ruled that the identification procedure was not impermissibly suggestive, upholding the credibility of Mr. Perias' eyewitness account. However, it also determined that while there were credible findings of guilt, the legal requirements for treachery as a qualifying circumstance for murder were not sufficiently averred in the information filed against DasmariAas. Consequently, the Court modified the ruling to find DasmariAas guilty of homicide rather than murder.
Constitutional Basis and Legal Standards
The Supreme Court applied the provisions of the 1987 Philippine Constitution, particularly regarding the right to a fair trial and the burden of proof required in criminal cases. The Court explained the necessity for allegations of qualifying circumstances in the indictment to be expressed distinctly in factual terms, not mer
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Case Overview
- Court: Supreme Court of the Philippines
- Decision Date: October 4, 2017
- Case Number: G.R. No. 203986
- Division: Third Division
- Judges: Bersamin, J. (Penwriting), with concurrence from Velasco, Jr., Leonen, Martires, and Gesmundo, JJ.
- Parties:
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: Jerson DasmariAas y Gonzales
Factual Background
- Incident Date: June 16, 2007
- Location: Las Piñas City, Philippines
- The case arose from the charge of murder against Jerson DasmariAas and Nino Polo, stemming from the shooting death of PO2 Marlon Anoya.
- The accusation included the circumstances of treachery, abuse of superior strength, and evident premeditation.
Procedural History
- Initial Charges: Filed by the Office of the City Prosecutor of Las Piñas on January 25, 2008.
- Arraignment:
- Polo pleaded not guilty on April 1, 2008.
- DasmariAas also entered a plea of not guilty on April 24, 2008.
- Trial: Witnesses for the prosecution included Aries Perias, the victim's widow Lourdes Anoya, SPO1 Roland Abraham, and Dr. Voltaire Nulud. The defense included Erica Camille Pascua and DasmariAas himself.
- RTC Decision: On January 10, 2011, the Regional Trial Court (RTC) found DasmariAas guilty of murder, sentencing him to reclusion perpetua, and ordered him to pay damages to the victim's widow.
- CA Ruling: The Court of Appeals (CA) affirmed the RTC's decision but modified the civil liabilities.
Key Evidence and Testimonies
Prosecution Witnesses:
- Aries Perias: Eyewitness who saw Dasmar