Case Summary (G.R. No. 247651)
Applicable Law
The relevant constitutional framework guiding this decision derives from the 1987 Philippine Constitution, particularly concerning the presumption of innocence and the burden of proof in criminal cases.
Charges and Initial Proceedings
Mark Ian Libunao was charged with homicide in the Information filed on January 5, 2015, alleging that he used his motor vehicle to unlawfully inflict harm on Acosta, resulting in fatal injuries. After his arraignment on January 26, 2015, where he pleaded not guilty, Libunao filed a Motion for Bail, asserting wrongful identification as the basis for his defense. The Regional Trial Court (RTC) granted bail, allowing Libunao to post a bond of P100,000.
Prosecution's Evidence
The prosecution presented several witnesses, including Traffic Constables Liberty Tongco and Lourdes S. Liton, and a civilian barker named Rommel P. Montipio. Their testimonies revealed that Acosta apprehended Libunao for traffic violations before the latter drove away, leading to Acosta falling and sustaining serious injuries. Specifically, Montipio testified he observed Libunao as the driver of the offending vehicle during the incident. The prosecution also included testimony from Acosta's wife regarding the impact of his death on their family and forensic evidence that established the cause of Acosta's fatal injuries.
RTC's Findings and Judgment
On February 16, 2017, the RTC convicted Libunao of homicide, ruling that all elements necessary to establish the crime had been proven. The RTC's judgment highlighted the intent to kill, as evidenced by Libunao's actions when he left the scene while Acosta was still partially within his vehicle. The court emphasized Libunao's flight from the scene as indicative of his guilt and acknowledged the financial and emotional damages suffered by Acosta's heirs, ordering significant monetary compensation payable to them.
Appeal to the Court of Appeals
Libunao appealed the RTC’s decision, maintaining that his identity was not proven beyond reasonable doubt. On May 9, 2018, the Court of Appeals (CA) affirmed the lower court's decision, dismissing the appeal for lack of merit. The CA's findings reiterated that Montipio's identification of Libunao, despite the tinted windows of the vehicle, was compelling enough to uphold the conviction.
Appellate Analysis and Supreme Court Decision
In assessing the appeal, the Supreme Court noted significant issues concerning the reliability of the so
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Case Overview
- The case is an appeal from the Decision dated May 9, 2018, of the Court of Appeals (CA) in CA-G.R. CR No. 40234.
- The CA affirmed the Judgment dated February 16, 2017, and the Order dated June 23, 2017, of the Regional Trial Court (RTC) of Quezon City, Branch 100, convicting Mark Ian Libunao y Mariano (appellant) of homicide.
- The appeal also contests the CA Resolution dated January 11, 2019, which denied the motion for reconsideration.
Charges and Incident Details
- The appellant was charged with murder in an Information dated January 5, 2015, for the death of Sonny Dela Cruz Acosta, an MMDA Traffic Enforcer, who was allegedly dragged by the appellant's vehicle after being apprehended for a traffic violation.
- The incident occurred on December 19, 2014, on EDSA in Quezon City.
- The Information detailed that the appellant, with intent to kill, used a motor vehicle to inflict serious and mortal injuries upon Acosta, leading to his death on December 23, 2014.
Arraignment and Pre-Trial Motions
- Upon arraignment, the appellant pleaded not guilty.
- A motion for bail was filed by the appellant, asserting wrongful identification as the basis for his defense.
- The RTC conducted hearings to determine the strength of the prosecution's evidence.
Prosecution Evidence
- Key witnesses for the prosecution included Liberty Tongco, Lourdes S. Liton, and Rommel P. Montipio, all of whom were prese