Case Summary (G.R. No. 234435-36)
Charges and Background
The information filed by the Provincial Prosecutor of Laguna charged Ebias with murder and frustrated murder, alleging that he, in conspiracy with an unknown accomplice, executed the attacks with evident premeditation, treachery, and abuse of superior strength. Ebias was arrested, and upon arraignment, he pleaded not guilty.
Prosecution's Evidence
The prosecution presented evidence including testimonies from Ronaldo Narez, who was injured in the shooting, and from witnesses who corroborated the events. Ronaldo recounted encountering two armed men while collecting jackfruit and subsequently being shot. On July 11, 1994, he identified his assailant as "Boy Marantal," later confirmed in an affidavit dated August 16, 1994, to be Ernesto Ebias. During the trial, Ronaldo maintained that Ebias was the shooter despite being unable to identify a companion of Ebias present at that time.
Defense's Argument
In contrast, the defense claimed that Ebias had an alibi, stating he was working in a nearby citrus plantation and was at home for lunch around the time of the incident. Defense witness Isagani Maray supported this alibi but acknowledged the plantation's proximity to the crime scene. The defense also presented arguments raising doubts about the reliability of the witness identification, emphasizing the absence of corroborating evidence regarding the alias "Boy Marantal."
Trial Court's Decision
On May 15, 1996, the trial court found Ebias guilty, imposing the death penalty, highlighting the credibility of Ronaldo's identification despite the defense’s challenges. The court ordered indemnity payments to the victims’ heirs for damages incurred.
Appeal and Newly-Discovered Evidence
Upon appeal, Ebias contended that the prosecution did not adhere to procedural rules protecting accused rights and relied heavily on the uncorroborated testimony of a single eyewitness. He also filed a motion for a new trial on the grounds of newly-discovered evidence—specifically, a confession from Leonardo Eliseo, another death row inmate, claiming responsibility for the crime. The prosecution opposed this motion, asserting the reliability of Ronaldo’s identification outweighed Eliseo's confession.
Court's Review on the Newly-Discovered Evidence
The Supreme Court evaluated whether Eliseo's confession satisfied the grounds for a new trial: (1) the evidence was discovered post-trial, (2) it could not have been previously discovered despite reasonable diligence, and (3) it was ma
...continue readingCase Syllabus (G.R. No. 234435-36)
Case Overview
- The case is an automatic review due to the Regional Trial Court's imposition of the death penalty on accused-appellant Ernesto Ebias for the complex crime of murder with frustrated murder.
- Accused-appellant seeks a new trial based on newly-discovered evidence.
Case Background
- On December 13, 1994, the accused and a John Doe were charged with murder and frustrated murder, as filed by the Provincial Prosecutor of Laguna.
- The information alleged that on July 8, 1994, in Barangay Dambo, Pangil, Laguna, accused-appellant, armed with a homemade gauge 12 shotgun, attacked and shot Ronaldo Narez and Tirso Narez.
- Tirso Narez died from multiple gunshot wounds, while Ronaldo sustained injuries but survived.
Facts of the Case
- On the day of the incident, Ronaldo and Tirso Narez were gathering jackfruit when they encountered two men who called out to them.
- After ignoring the men, one of them brandished a bolo and instructed the other to shoot.
- The accused shot both victims; Tirso died the following day in the hospital, while Ronaldo survived and later identified the shooter as "Boy Marantal."
Evidence Presented
- Ronaldo Narez's initial affidavit identified the shooter as "Boy Marantal," who he claimed he could recognize if he saw him again.
- A month later, Ronaldo executed a second affidavit identifying Ernesto Ebias as the shooter after recognizing him upon returning to their barangay.
- During the trial, Ronaldo maintained that accused-appellant and Boy Marantal were the same person but could not identify the other man involved due to his face being covered.