G.R. Nos. L-17402 & L-17403; August 31, 1963
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FELICIANO RAMOS alias CIANO, defendant-appellant.
FACTS
The accused, Feliciano Ramos, was charged with illegal possession of a firearm and murder for the killing of Ricardo Nodora on February 20, 1959, in Luna, La Union. The prosecution presented eyewitness Saturnino Velasco, who testified that he saw Ramos shoot Nodora from behind on the beach. The prosecution also introduced two sworn confessions (Exhibits B and D) executed by Ramos before Justices of the Peace Antonio Bautista and Pedro Arciaga, wherein he admitted to the killing and ownership of the unlicensed .45 caliber pistol used in the crime. Ramos, interposing an alibi, claimed he was fishing at sea at the time and asserted that his confessions were extracted through violence and maltreatment by Constabulary officers.
ISSUE
The primary issues were: (1) whether the confessions were voluntarily executed and thus admissible, and (2) whether the prosecution evidence, particularly the eyewitness account, sufficiently established Ramos’s guilt beyond reasonable doubt for both crimes.
RULING
The Supreme Court affirmed the convictions but modified the penalty for illegal possession. The Court upheld the trial court’s finding that the confessions were voluntary. Justices of the Peace Bautista and Arciaga testified that they thoroughly cautioned Ramos, explained the contents in Ilocano, and ascertained that he was signing freely without coercion. Their testimonies outweighed Ramos’s bare allegations of maltreatment, which he failed to substantiate. The positive identification by eyewitness Saturnino Velasco was deemed credible and sufficient to convict Ramos of murder. The Court noted that alibi is a weak defense, especially when contradicted by positive identification from a disinterested witness with no motive to falsify. Velasco’s immediate identification of Ramos in an affidavit corroborated his trial testimony. Regarding the firearm, the Court found Ramos guilty of illegal possession as he failed to present any license for the pistol he surrendered. The penalty was modified to an indeterminate sentence of two to five years of imprisonment. The murder conviction and corresponding penalty of reclusion perpetua were affirmed.
