G.R. No. 72744-45 April 18, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO MANAMBIT, JAIME MANAMBIT, FELICIANO RANA, BENJAMIN LACBAY, RAMON MAMURI and MAURICIO LLAMES, accused, JIMMY MANAMBIT, MAURICIO LLAMES and RAMON MAMURI, accused-appellants.

FACTS

This case stems from a violent feud between the Manambit and Samonte families. On August 29, 1978, in Pagsanjan, Laguna, Hector Samonte was driving a motorcycle with Reynaldo Baldemora as his backrider. They were ambushed by armed men. Baldemora was shot and killed, while Samonte sustained gunshot wounds but survived. The prosecution’s case relied heavily on the testimony of Hector Samonte, who identified appellants Jimmy Manambit, Mauricio Llames, and Ramon Mamuri as the assailants. He testified that he clearly saw Jimmy Manambit fire at them and recognized the others. The defense consisted of alibis and denials, claiming the accused were elsewhere during the incident.
The Regional Trial Court convicted Jimmy Manambit as principal for Murder and Frustrated Murder, imposing the death penalty for Murder. Llames and Mamuri were convicted as accomplices for both crimes. Three other accused were acquitted. The case was elevated to the Supreme Court on automatic review due to the death penalty and via appeal by the other convicted appellants.

ISSUE

The main issue is whether the guilt of the appellants was proven beyond reasonable doubt based on the identification by the lone eyewitness, Hector Samonte, amidst the backdrop of a family feud.

RULING

The Supreme Court affirmed the convictions but modified the penalties. The Court found the testimony of Hector Samonte credible and sufficient to establish guilt beyond reasonable doubt. As the victim, Samonte had a clear view of his attackers during the startling incident, and his immediate identification of Jimmy Manambit to his brother shortly after the shooting was admissible as part of the res gestae. His positive identification prevails over the weak defenses of alibi and denial proffered by the appellants. The existence of a family feud provided a strong motive for the attack, corroborating the witness account. However, the Court found that the qualifying circumstances of treachery and abuse of superior strength were not proven with certainty, as the attack was frontal and sudden, not from behind. Consequently, the crime is Homicide, not Murder. The death penalty was thus reduced to an indeterminate penalty. The Court upheld the accomplice liability of Llames and Mamuri, as their presence and actions aided in the commission of the crime. The awards for damages were also modified in accordance with prevailing jurisprudence.