Case Summary (G.R. No. 98069)
Charge and Proceedings
Both accused were charged with the crime of murder, which included allegations of treachery and evident premeditation resulting in the death of Camilo Mamuyac. Upon arraignment, they both pleaded not guilty, leading to a trial involving six prosecution witnesses and a single defense witness, aside from the accused. The trial ultimately resulted in Ramon Flores being found guilty, while Renato Macabiog was acquitted due to insufficient evidence.
Trial Court Verdict
The trial court found Ramon Flores guilty beyond reasonable doubt and sentenced him to a penalty of reclusion temporal for a maximum period of 17 years, 4 months, and 1 day to 20 years, along with a monetary indemnity of P30,000 to the victim’s heirs. Conversely, Renato Macabiog was acquitted.
Appeal to the Court of Appeals
Flores appealed to the Court of Appeals, which gathered evidence including witness testimonies recounting the events surrounding the murder. The court found corroborative evidence, noting witness accounts of the moments leading up to and following the shooting, as well as a paraffin test on Flores indicating his possible involvement.
Eyewitness Testimony and Credibility Issues
Evangeline Mamuyac, the victim's wife and key eyewitness, testified to witnessing the shooting. Appellant Flores challenged her credibility, arguing that her observations were improbable, and that her testimony was uncorroborated. However, the Court of Appeals found her testimony plausible, maintaining that human reactions to trauma can vary and that immediate disclosure of the assailant's identity is not always feasible.
Defense and Counterarguments
The defense centered on denials and alibi, primarily presented by Flores and his mother, who claimed he was engaged in a family conversation during the time of the murder. The appellate court scrutinized this defense and found contradictions and a lack of solid proof to support the alibi, which was further undermined by the presence of gunshot residue on Flores’ hands.
Reaffirmation of Guilt
The appellate court upheld the trial court's findings, asserting that the prosecution successfully established guilt beyond a reasonable doubt. The court also noted the absence of physical impossibility for Flores to be at the scene of the crime at the pertinent time. Furthermore, the motives for the crime, aggravated by previous threats made by Flores, were also considered compelling.
Sentencing and Final Ru
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Case Overview
- The case involves the charges of murder against Ramon Flores and Renato Macabiog.
- The incident occurred on October 15, 1979, in Maglaoi Centro, Currimao, Ilocos Norte, Philippines.
- The charge against the accused includes conspiracy, treachery, and evident premeditation in the killing of Camilo Mamuyac.
- The accused were alleged to have attacked and shot the victim, resulting in his instantaneous death.
Charges and Proceedings
- The information filed against the accused detailed the circumstances surrounding the murder, including the time and location.
- Both accused pleaded not guilty during their arraignment.
- The prosecution presented six witnesses, including family members and medical professionals, to establish the case against Ramon Flores.
- The defense presented one witness in addition to the two accused, claiming an alibi.
Trial Court Verdict
- On September 5, 1989, the trial court found Ramon Flores guilty beyond reasonable doubt of murder with treachery.
- The court sentenced Flores to reclusion temporal for a maximum period of 17 years and 4 months to 20 years, along with civil indemnities to the heirs of the victim amounting to P30,000.
- Renato Macabiog was acquitted due to insufficient evidence.
Appeal to the Court of Appeals
- Ramon Flores appealed the trial court's decision to the Court of Appeals.
- The appellate court confirmed the findings of the trial court but i