CASE DIGEST
PEOPLE V. MANANSALA Y
ALFARO
G.R. No. 233104, September
2, 2020
SECOND DIVISION, HERNANDO
J.
Murder, Treachery,
Evident Premeditation, Ciscumstantial Evidence
DOCTRINE: Circumstantial evidence can be sufficient to support a conviction in the absence of direct evidence, as long as the circumstances proved form an unbroken chain leading to a fair and reasonable conclusion pointing to the accused as the perpetrator, to the exclusion of all others.
Manansala y Alfaro, was charged with murder for the killing Armando Ramos y Santos. The prosecution presented eyewitness testimonies, along with CCTV footage that showed a man resembling Manansala entering the victim's house, shooting him, and quickly leaving. The medical findings indicated that the gunshot wound was at the victim's back, which was fatal. They argued that treachery and evident premeditation were present. Manansala denied the charges, claiming he was in Bulacan during the incident.
RTC found accused guilty considering
treachery and evident premeditation based on the altercation between the victim
and Manansala before the incident. The Court of Appeals affirmed the RTC's decision,
relying on the corroborated eyewitness testimonies and the CCTV footage, which
clearly identified Manansala as the perpetrator.
Whether the appellant is guilty of murder and
whether treachery and evident premeditation were present during the commission
of the crime.
YES. In this case, the death of the victim Ramos is undisputed. The court relied on circumstantial evidence, which sufficiently supported the finding that Manansala was the perpetrator of the crime. Circumstantial evidence, also known as indirect or presumptive evidence, refers to proof of collateral facts and circumstances whence the existence of the main fact may be inferred according to reason and common experience.
As to the qualifying circumstances, treachery was confirmed based on the sudden and unexpected attack from behind, as seen in eyewitness accounts and CCTV footage. However, the court concluded that the prosecution failed to satisfactorily prove the presence of evident premeditation. The essence of evident premeditation is that the execution of the criminal act must be preceded by cool thought and reflection. Evident premeditation must be based on external acts and must be evident, not merely suspected, indicating deliberate planning.
Nevertheless, the killing remains
murder due to the presence of treachery.
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