Case Summary (G.R. No. 190340)
Factual Antecedents
On June 28, 2006, Rogelio and Marissa were charged with murder under Article 248 of the Revised Penal Code (RPC). The prosecution alleged that on the evening of April 11, 2006, the accused conspired to kill Abacco using bladed weapons while he was defenseless. The charging document specified treachery and abuse of superior strength as aggravating circumstances. Upon arraignment, both appellants pleaded not guilty, leading to a trial.
Version of the Prosecution
The prosecution presented a comprehensive case with testimonies from eight witnesses, including law enforcement and medical personnel. Their accounts indicated that Rogelio attacked Abacco with a samurai sword after provocative actions taken by Rogelio and Marissa, who subsequently encouraged the assault despite Abacco's pleas for mercy. Forensic evidence from Dr. Arsenio Parazo confirmed that Abacco died from numerous life-threatening wounds sustained in the attack.
Version of the Defense
The defense offered conflicting narratives, asserting that Rogelio acted in self-defense against Abacco, who allegedly initiated the violence by attacking him with a bolo. Marissa claimed she was not present during the attack, providing an alibi that failed to meet the legal standards for creating physical impossibility. Their testimonies were contradicted by substantial evidence and witness accounts placing them at the scene during the incident.
Ruling of the Regional Trial Court
The Regional Trial Court (RTC) sentenced both accused to reclusion perpetua, finding them guilty of murder on February 28, 2007. The court rejected the self-defense claim, stating that once the accused began their attack, any unlawful aggression from the victim ceased. The RTC also ruled that the vicious nature of the assault illustrated a motive to kill, not merely to defend oneself.
Ruling of the Court of Appeals
Upon appeal, the Court of Appeals upheld the RTC's decision while modifying the damage awards. The appellate court reasoned that the appellants failed to prove self-defense and characterized Rogelio's actions as retaliation marked by treachery, given the premeditated and coordinated nature of the attack.
Assignment of Errors
Dissatisfied with the Court of Appeals' ruling, the appellants raised multiple claims of error, including a challenge to the sufficiency of the proof of guilt and the credibility of prosecution witnesses, along with a dispute over the assertion of treachery during the murder.
Our Ruling
The Supreme Court rejected the appeal, maintaining that Rogelio's acknowledgment of involvement in Abacco's death necessitated proof of self-defense, which he failed to establish. The court concluded that the alleged aggression from Abacco, characterized as unarmed and inviting dialogue, did not constitute a justifiable cause for the lethal response. Furthermore, it found no merit in Marissa's alibi
...continue readingCase Syllabus (G.R. No. 190340)
Background of the Case
- The case involves the appeal of Rogelio Ramos and Marissa Intero Ramos against their conviction for murder.
- The appeal is from the September 9, 2009 Decision of the Court of Appeals (CA) which affirmed with modification the February 28, 2007 Decision of the Regional Trial Court (RTC) of Agoo, La Union.
- The RTC found both accused guilty beyond reasonable doubt of murder under Article 248 of the Revised Penal Code (RPC).
- They were sentenced to reclusion perpetua and ordered to pay civil indemnity and moral damages to the heirs of the victim, Ronald A. Abacco.
Factual Antecedents
- The appellants were charged with murder stemming from an incident on April 11, 2006, in Sto. Tomas, La Union.
- The Information against them indicated that they conspired to kill Abacco using their superior strength and a bladed weapon.
- The charge included the qualifying circumstances of treachery and abuse of superior strength.
Prosecution's Version
- Eight witnesses testified for the prosecution, detailing the events leading to Abacco's death.
- On the evening of the incident, Rogelio threw stones at his brother-in-law's house where Abacco and others were resting.
- Following a confrontation, when Abacco approached the Ramos residence unarmed, Rogelio attacked him with a samurai sword.
- After Abacco fell, both appellants continued to assault him; Marissa encouraged Rogelio to kill Abacco.
- The autopsy revealed Abacco died from massive blood loss due to multiple hacked wounds.
Defense's Version
- The defense presented six wit