G.R. No. 101435 November 8, 1993
People of the Philippines, plaintiff-appellee, vs. Benjie Ramilla y Ausente alias “Chem-Chem,” accused-appellant.

FACTS

On September 1, 1988, at about 9:00 PM on Quirino Street in Tondo, Manila, Edgar “Egay” Santos and his friend William Santos were passing by a store where the accused-appellant Benjie Ramilla and his companions were drinking. Upon seeing them, Ramilla’s group whispered among themselves. Ramilla then approached William, grabbed his hair, and dragged him about five meters away. Demetrio Cabretino handed a knife to Roberto Castillo, who proceeded to stab William while two others held the victim’s arms. Ramilla kicked William several times before the victim fell to the ground. Egay reported the incident to William’s father, and they rushed him to the hospital where he was pronounced dead. The autopsy report indicated the cause of death was massive hemorrhage due to a stab wound on the chest. Egay later accompanied policemen to Ramilla’s house, where they found him hiding behind a table in the kitchen; he was invited to police headquarters for questioning. Ramilla was charged with murder as his companions had disappeared. He pleaded denial and alibi, testifying he was asleep at home that night under his parents’ orders. His mother, Adelaida Ramilla, corroborated his alibi and suggested Egay had a motive to testify falsely due to a prior falling-out. Two defense witnesses, Arturo Esplago and Demetrio Mata, testified that a stranger from an alley stabbed William. The Regional Trial Court of Manila found Ramilla guilty of murder and sentenced him to reclusion perpetua, with civil indemnity and moral damages.

ISSUE

The primary issue is whether the trial court erred in convicting the accused-appellant of murder based on the prosecution’s evidence, rejecting the defense of alibi and the testimonies of defense witnesses, and in its appreciation of the circumstances of conspiracy, treachery, and evident premeditation.

RULING

The Supreme Court dismissed the appeal and affirmed the trial court’s decision. The Court held that the equipoise rule was inapplicable as the prosecution’s evidence was heavier and overcame the constitutional presumption of innocence. The testimony of prosecution eyewitness Egay Santos was found credible, swift, and consistent from his initial sworn statement to his trial testimony, with no time for fabrication. In contrast, the defense’s alibi was weak, as Ramilla’s house was only a few minutes from the crime scene, and the corroboration by his mother was suspect due to bias. The testimonies of defense witnesses Esplago and Mata were unreliable, containing inconsistencies (e.g., where the victim fell) and unnatural details (e.g., the victim shouting “Away! Away!” instead of calling for help, and clutching his stomach despite a chest wound). The trial court’s assessment of witness credibility was respected. Conspiracy was established through the group’s whispered conversation, coordinated actions in dragging, restraining, stabbing, and kicking the victim, showing community of purpose. Treachery qualified the killing as murder, as the attack was sudden and rendered the victim unable to defend himself. However, evident premeditation was not proven, as there was no evidence of a pre-conceived plan or sufficient time for reflection; the trial court’s statement that conspiracy denotes premeditation was corrected as an overgeneralization. The mitigating circumstance of voluntary surrender was not appreciated, as Ramilla was found hiding by police and did not voluntarily present himself. The penalty of reclusion perpetua and awards for civil indemnity and moral damages were upheld.