Case Summary (G.R. No. 232338)
Charges and Background
Ramon was charged with murder under Article 248 of the Revised Penal Code. The Information alleged that he, with intent to kill, treachery, and evident premeditation, shot Vivien twice in the head, resulting in her death. The prosecution presented multiple witnesses who testified about the incident occurring when Vivien was walking with her companions when a motorcycle approached, and an assailant shot her without warning.
Defense Claims
During the trial, Ramon asserted his innocence, claiming he was elsewhere at the time of the incident. He provided a narrative that he was seeking money for his son's school shoes before proceeding to the hospital where his first wife was confined. Additionally, he faced allegations of police coercion regarding a separate incident of which he was a victim.
RTC Ruling
After the trial concluded, the RTC found Ramon guilty beyond reasonable doubt, sentencing him to reclusion perpetua and requiring him to pay civil indemnity and damages to Vivien's heirs. The court ruled that the killing was committed with treachery, as the assault took place suddenly, leaving the victim unsuspecting.
Appeal and CA Ruling
Ramon appealed the RTC’s decision, arguing insufficient identification and the absence of treachery. The CA upheld the RTC ruling, asserting that the evidence sufficiently proved Ramon’s guilt, specifically highlighting the witnesses’ accounts concerning the sudden nature of the attack.
Issues for Resolution
The principal issues considered by the higher court were whether the prosecution witnesses positively identified Ramon as the shooter and whether the presence of treachery qualified the crime as murder.
Supreme Court's Analysis
Upon review, the Supreme Court found the lower courts erred in establishing Ramon's guilt based on the eyewitness identification. Several factors highlighted the unreliability of the witnesses' testimonies: differing accounts of the assailant's height and demeanor, the position from which they viewed the crime, and inconsistencies in their stateme
...continue readingCase Syllabus (G.R. No. 232338)
Case Citation
- 856 Phil. 123
- G.R. No. 232338
- Promulgated on July 08, 2019
Parties Involved
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: Ramon Quillo y Esmani
Background of the Case
- The case is an appeal from the August 30, 2016 Decision of the Court of Appeals (CA), which affirmed the Regional Trial Court's (RTC) finding of guilt against Ramon Quillo for Murder under Article 248 of the Revised Penal Code.
- The RTC sentenced Ramon to reclusion perpetua and ordered him to pay damages to the heirs of the victim, Vivien Yap-De Castro.
Antecedents of the Case
- The Information filed against Ramon alleged that on May 28, 2014, in Quezon City, he, with intent to kill and with qualifying circumstances of treachery and evident premeditation, shot Vivien twice in the head, leading to her death.
- Key prosecution witnesses included Audrey Phoebe Yap-Lopez, Michael M. Marinas, Gina A. Besmonte, Corazon D. Dasig, and PO2 Jogene Hernandez.
- Eyewitnesses testified that Ramon was the back rider of the motorcycle that approached the victim and shot her.
Evidence Presented
- Eyewitness testimonies indicated that the assailant was not wearing a helmet, allowing witnesses to see his face.
- The Medico-Legal Report confirmed the gunshot wounds as the cause of death.
- Ramon claimed he was elsewhere at