GR 130213; (January, 2002) (Digest)
G.R. No. 130213 ; January 31, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAMIL MARQUINA, accused-appellant.
FACTS
Accused-appellant Ramil Marquina was charged with Murder for the stabbing death of Enrico Gaon on August 17, 1991, in Pasig. The prosecution’s case primarily hinged on the alleged dying declaration of the victim. The victim’s brother, Romel Gaon, testified that upon finding the victim in a canal, he lifted him and asked who was responsible. Romel claimed the victim, with his mouth five inches from Romel’s ear, clearly uttered “Ramil Marquina!” twice before dying shortly after. The trial court convicted Marquina of Murder qualified by treachery and sentenced him to reclusion perpetua, acquitting his co-accused.
ISSUE
Whether the conviction of accused-appellant Ramil Marquina for Murder, based primarily on the alleged dying declaration, is sustainable beyond reasonable doubt.
RULING
No. The Supreme Court reversed the conviction and acquitted Marquina. The Court found the alleged dying declaration unreliable and insufficient to sustain a conviction. The legal logic centered on the inherent improbability of the declaration given the victim’s physical condition. The autopsy revealed forty-eight wounds, including two fatal stab wounds to the neck that lacerated the trachea and the left common carotid artery. The medical expert testified that such injuries would have caused immediate loss of voice and rapid loss of consciousness, making it medically impossible for the victim to have spoken the name “Ramil Marquina” clearly and twice several minutes after the attack. The Court emphasized that physical evidence holds greater weight than testimonial evidence when they are irreconcilable. Since the prosecution’s sole direct evidence was the dying declaration, and it was utterly inconsistent with the incontrovertible physical evidence of the victim’s catastrophic injuries, the prosecution failed to prove Marquina’s guilt beyond reasonable doubt. The constitutional presumption of innocence therefore prevailed.