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PEOPLE v. RAMIL ANTIGUA Y QUILA

FACTS:

In this case, Ramil Antigua y Quila (Ramil) appealed the Resolutions of the Court of Appeals (CA) dismissing his appeal of the Judgment and Resolution of the Regional Trial Court (RTC) convicting him of murder. Ramil, along with John Doe and Peter Doe, was charged with murder for shooting, stabbing, and hacking Mario Canaria, which resulted in his death. Ramil pleaded not guilty and presented his own witnesses.

Plaintiff-appellee presented witnesses who testified that Ramil was one of the assailants who shot Mario. They claimed that Ramil was motivated by the fact that Mario had testified against him in a case for illegal logging. The witnesses also mentioned that Ramil shouted a specific phrase before the shooting, which was later used to identify him.

Ramil presented an alibi defense, stating that he was at a different location during the time of the incident. He claimed that he was drinking with friends and sleeping at his sister's house.

The RTC found Ramil guilty beyond reasonable doubt of murder and sentenced him to reclusion perpetua. The RTC relied on the testimonies of the plaintiff-appellee's witnesses and disregarded Ramil's alibi defense.

Ramil's appeal to the CA was dismissed due to his failure to file the appellant's brief within the reglementary period. The CA denied his motion for reconsideration.

ISSUES:

  1. Whether the CA erred in dismissing Ramil's appeal.

  2. Whether Ramil is guilty of murder.

  3. Whether Ramil should be held liable as a principal or an accomplice in the crime of murder.

  4. What penalty should be imposed on Ramil as an accomplice.

  5. Whether Ramil can be held subsidiarily liable for the civil damages awarded if the principal dies before the finality of the decision.

  6. The main issue in this case is whether the accused is guilty of the crime of murder.

RULING:

  1. The Court partially grants the appeal. The CA was within its discretion to dismiss Ramil's appeal for failing to file his appellant's brief on time. However, the Court will determine the merits of Ramil's appeal considering that his personal liberty is at stake. The RTC correctly found Ramil guilty of murder based on the elements and attending circumstances of the crime.

  2. Ramil should be held liable as an accomplice in the crime of murder. While he participated in the incident by identifying the victim and standing by while his companions attacked the victim, his acts were not indispensable to the murder of the victim. There was no proof that the other assailants could not have carried out their attack on the victim without Ramil's assistance. Moreover, there was no evidence that Ramil previously entered into an agreement with the assailants to attack the victim.

  3. The proper penalty for Ramil as an accomplice in murder is the penalty next lower in degree than that prescribed for the consummated felony. In this case, the penalty next lower in degree is reclusion temporal. Since there are no mitigating or aggravating circumstances, the penalty of imprisonment imposed on Ramil should be in its medium period.

  4. Ramil cannot be held subsidiarily liable for the civil damages awarded if the principal dies before the finality of the decision. The principal's death would extinguish their civil liability.

  5. The accused is found guilty beyond reasonable doubt of the crime of murder and is sentenced to suffer the penalty of reclusion perpetua. He is also ordered to pay the heirs of the victim various amounts as civil indemnity, moral damages, exemplary damages, and temperate damages, with interest at six percent (6%) per annum from the finality of the decision until full satisfaction.

PRINCIPLES:

  • Procedural rules take a step back when it would subvert or frustrate justice, especially when the life and liberty of the accused is at stake.

  • The crime of murder is proven when the elements and attending circumstances are established, including the killing of a person, the participation of the accused, the presence of qualifying circumstances, and the absence of parricide or infanticide.

  • Treachery is present when the offender employs means, methods, or forms of execution that directly and specially ensure the killing without risk to himself arising from the defense of the victim.

  • Presence during the commission of a crime can be proven through testimonial evidence, such as identifying the accused's voice.

  • The sound of a person's voice is an acceptable means of identification if the witness and the accused knew each other personally and closely for a number of years.

  • A person may be considered an accomplice if there is a community of design with the principal, cooperation in the execution by previous or simultaneous acts, and a relation between the acts done by the principal and those attributed to the person charged as an accomplice.

  • Mere presence at the crime scene is not sufficient proof of conspiracy.

  • The penalty for an accomplice is the penalty next lower in degree than that prescribed for the consummated felony.

  • Subsidiary liability of an accomplice for civil damages is extinguished if the principal dies before the finality of the decision.

  • The proper civil damages to be awarded to the heirs of the victim in a murder case are: P75,000.00 as civil indemnity, P75,000.00 as moral damages, P75,000.00 as exemplary damages, and P50,000.00 as temperate damages. As an accomplice, liability for these damages is reduced to 1/5 of the amounts granted to the heirs of the victim.

  • Proof beyond reasonable doubt - The guilt of the accused must be proven beyond reasonable doubt for a conviction in criminal cases.

  • Murder - Murder is the unlawful killing of a person which is qualified by certain circumstances that elevate the crime to a more severe category.

  • Reclusion perpetua - Reclusion perpetua is the penalty imposed for the crime of murder, in which the accused is sentenced to suffer imprisonment for a period of at least thirty (30) years to forty (40) years, without eligibility for parole.

  • Civil indemnity - Civil indemnity is the amount awarded to the heirs of the victim to compensate for the loss of their loved one.

  • Moral damages - Moral damages are awarded to the heirs of the victim to compensate for the mental anguish, emotional suffering, and moral shock caused by the crime.

  • Exemplary damages - Exemplary damages are awarded to the heirs of the victim as a punishment to the accused and as a deterrent to similar acts in the future.

  • Temperate damages - Temperate damages are awarded when the amount of actual damages cannot be proven with certainty, but it is clear that the victim suffered some form of pecuniary loss.

  • Interest - Interest can be imposed on the monetary award from the finality of the decision until its full satisfaction, at a rate determined by the court.