People vs. Manansala

Murder may be established through circumstantial evidence that forms an unbroken chain pointing to the accused to the exclusion of all others, and treachery qualifies the killing when the victim is shot from behind while going upstairs, leaving him no chance to defend himself; evident premeditation, however, requires proof of deliberate planning and sufficient lapse of time, not mere resentment from a prior confrontation.

Manansala and Armando Ramos had a longstanding acquaintance, with Manansala doing repairs for Ramos’s electricity and water supply, according to the defense. Under Article 248 of the Revised Penal Code, Murder is committed when a person is killed with any of the qualifying circumstances, including treachery and evident premeditation, and the killing is not parricide or infanticide.

• Original Filing: The Information was filed with the RTC, Branch 25, Manila, charging Manansala with Murder for the November 2, 2013 shooting of Armando Ramos in Manila, alleging treachery and evident premeditation; Manansala pleaded “not guilty” during arraignment.
• Lower Court Decision: RTC, Oct. 20, 2015 — convicted Manansala of Murder, sentenced him to reclusion perpetua, and ordered him to pay P107,286.17 actual damages, P75,000 civil indemnity, and P50,000 moral damages, relying on eyewitness accounts, CCTV footages, treachery, and evident premeditation.
• Appeal: CA, Jan. 5, 2017 — affirmed the conviction, held that treachery and evident premeditation attended the killing, imposed reclusion perpetua without eligibility for parole, and increased civil indemnity, moral damages, and exemplary damages to P100,000 each plus actual damages and 6% interest.
• SC Action: Manansala appealed to the SC; the SC, Sept. 2, 2020, dismissed the appeal and affirmed the CA with modification, finding treachery but not evident premeditation, and reducing the damages.

On November 2, 2013, around 8:00 p.m., Edward Reyes and his brother Elmer Reyes were in front of their rented apartment owned by Armando Ramos at No. 2637 Severino Reyes Street, Tondo, Manila, where Ramos also resided. The Reyes brothers were watching Renato Mananquil play guitar beside the door of their rented apartment when they heard a gunshot inside the house. Edward then saw Eddie Manansala facing the stairs, holding a gun aimed upwards. Manansala hurriedly left toward Lico Street while still holding a gun. Shouts and commotion followed upstairs, and Edward saw Ramos fall from the stairs with blood oozing from his left chest. According to the prosecution, Corazon Ramos, the victim’s wife, was taking a bath on the second floor when Manansala came and shot her husband; upon hearing the gunshot, she ran and saw her husband lying at the bottom of the stairs covered in blood. Asas Ramos, the victim’s son, also heard the gunshot and his father’s shout, ran to the door, and saw his father falling down the stairs. Several onlookers rushed Ramos to the Chinese General Hospital; Corazon followed but upon arrival was told her husband had already expired.

A concerned citizen reported the shooting to the police. PO1 Marinito Daya and PO1 Tuazon went to verify the report. Upon confirmation, Police Superintendent Roderick Mariano formed a team headed by PSI Alvin Balagat to conduct a follow-up and hot pursuit operation. Corazon requested that Ramos’s cadaver be examined by Dr. Romeo Salen. The medical findings indicated that the entry point of the gunshot wound was at the victim’s back, particularly the lumbar region, while the exit point was at the front portion of the body; the trajectory of the bullet was upward, and the distance between the muzzle of the gun and the victim’s body was about two feet or more. The gunshot wound fatally lacerated the lungs and heart and caused the victim’s death. On November 6, 2013, PSI Balagat’s team received information that Manansala was hiding in San Jose Del Monte, Bulacan, and coordinated with Chief PSupt. Joel Estaris. The next day, PSI Balagat and his team went to San Jose Del Monte after receiving information from CPSupt. Estaris that Manansala was already in their custody; they verified his identity and brought him to Jose Abad Santos Police Station (PS-7), Manila Police District, for verification, then turned him over to the MPD’s Crime Against Person Section.

During trial, CCTV footages of the crime scene were presented in court, showing a man appearing to be Manansala entering the house armed with a gun, proceeding upstairs, aiming his gun, shooting the victim, and immediately leaving the house. Asas testified that he transferred the video footages from the barangay-owned CCTV located outside their house to the compact disc submitted in court; when the footage was played and the enlarged screenshot presented, he identified the person as Manansala and the perpetrator of the crime. Barangay Kagawad Jume Piojo confirmed the location of the CCTV and testified that before the killing there were several complaints against Manansala concerning illegal electric connections or jumpers, which became the subject of an altercation between Manansala and Ramos one day before the latter was killed.

Manansala, for his part, averred that on November 2, 2013, around 7:00 p.m., he was on his way to Bulacan to visit his friend Allan Bautista. While on his way, he passed by Ramos’s house, then took the bus bound for Bulacan and arrived past 8:00 p.m. On November 3, 2013, he was surprised when his daughter Kiera informed him that he was the suspect in Ramos’s killing and that the killing was all over the local news. He denied killing Ramos and planned to surrender to a certain “Col. Pascual,” Kiera’s godparent. However, on November 5, 2013, he was suddenly arrested in Bautista’s home by police forces of San Jose Del Monte, Bulacan. He denied the allegations and owning a gun, and claimed that Ramos had ill-feelings toward him because of the jumpers he installed, which Manansala claimed even benefitted Ramos and his tenants. Kiera corroborated his story.

The RTC gave weight to the eyewitness accounts and CCTV footages, which pointed to Manansala as the author of the crime. It found that the shooting was sudden and unexpected, leaving the victim no chance to defend himself, and that the medical findings showed the entrance of the fatal gunshot wound was at the victim’s back. It also noted the prior public confrontation and altercation between the victim and Manansala over the alleged installation of electric jumpers.

• Identity of the Perpetrator: Manansala argued that the RTC gravely erred in finding him guilty despite the insufficiency of the prosecution’s evidence to prove that he was the one who shot the victim.
• Qualifying Circumstances: Manansala argued that the RTC gravely erred in finding him guilty despite the prosecution’s failure to sufficiently establish the existence of treachery and evident premeditation.
• Authentication of CCTV Footages: Manansala argued before the CA that Asas was not qualified to authenticate the CCTV footages because he was not the one who made the recording and the CCTV was owned by the barangay.

• Identity of the Perpetrator: Whether the prosecution proved beyond reasonable doubt that Manansala was the person who shot and killed Armando Ramos.
• Treachery: Whether treachery attended the killing.
• Evident Premeditation: Whether evident premeditation attended the killing.
• Authentication of CCTV Footages: Whether the CCTV footages were properly authenticated and admitted in evidence through Asas.
• Penalty and Civil Liability: Whether the penalty and monetary awards should be modified in light of the qualifying circumstances proved.

• Identity of the Perpetrator: Yes. Circumstantial evidence formed an unbroken chain pointing to Manansala, corroborated by eyewitnesses and CCTV footages.
• Treachery: Yes. The victim was shot from behind while going upstairs, rendering him defenseless against the sudden attack.
• Evident Premeditation: No. The only basis was a prior confrontation one day before the killing; there was no proof of deliberate planning and sufficient lapse of time.
• Authentication of CCTV Footages: Yes. The Rules on Electronic Evidence allow a competent witness who can testify to the accuracy of the recording to authenticate it; Asas established its origin and transfer.
• Penalty and Civil Liability: Penalty is reclusion perpetua; civil indemnity, moral damages, and exemplary damages are P75,000 each, plus P107,286.17 actual damages and 6% interest from finality.

• Identity of the Perpetrator: The SC began from the rule that an appeal in a criminal case opens the entire case for review, and the prosecution must prove the elements of Murder and the qualifying circumstances beyond reasonable doubt. The death of Ramos was undisputed, and the killing was neither parricide nor infanticide. Absence of direct evidence did not bar conviction because circumstantial evidence can sustain conviction when there is more than one circumstance, the facts from which inferences are derived are proven, and the combination produces conviction beyond reasonable doubt; the circumstances must form an unbroken chain pointing to the accused to the exclusion of all others. The SC found six circumstances: Edward saw Manansala holding a gun aimed at the stairs after the gunshot; Manansala ran toward Lico Street; Edward then saw Ramos bloodied and unconscious; Mananquil saw Manansala coming out of Ramos’s house after the gunshot; Mananquil later saw Ramos lying down; and the CCTV and printouts corroborated Edward and Mananquil. These convincingly pointed to Manansala as the killer.
• Treachery: Article 14, paragraph 16, Revised Penal Code defines treachery as the direct employment of means, methods, or forms in the execution of the crime against persons which tend directly and specially to insure its execution, without risk to the offender arising from the defense which the offended party might make. The essence of treachery is that the attack is deliberate and without warning, done in a swift and unexpected way, affording the hapless, unarmed and unsuspecting victim no chance to resist or escape. Two elements must be present: the victim was not in a position to defend himself at the time of the attack, and the accused consciously and deliberately adopted the particular means, methods, or forms of attack employed. These elements were present: Manansala stealthily entered the victim’s house and shot him while he was going upstairs. The fatal wound was inflicted from behind since the entry point was at the back lumbar region while the exit point was at the front portion of the body with the trajectory traversing upwards, clearly indicating that the victim was going upstairs with his back toward the assailant when he was shot. The victim’s position rendered him defenseless from the sudden attack from behind, and the CCTV footages corroborated the prosecution witnesses.
• Evident Premeditation: The elements of evident premeditation are: a previous decision by the accused to commit the crime; an overt act or acts manifestly indicating that the accused clung to his determination; and a lapse of time between the decision to commit the crime and its actual execution sufficient to allow the accused to reflect upon the consequences of his acts. These circumstances were not present. The only basis for the RTC and the CA in finding evident premeditation was the confrontation between the victim and Manansala one day before the killing; the trial court merely surmised that Manansala must have harbored feelings of resentment toward the victim and clung to that thought and killed the victim. The essence of evident premeditation is that the execution of the criminal act must be preceded by cool thought and reflection upon the resolution to carry out the criminal intent, during the space of time sufficient to arrive at a calm judgment. When it is not shown how and when the plan to kill was hatched or what time had elapsed before it was carried out, evident premeditation cannot be considered; it must be based on external acts and must be evident, not merely suspected, indicating deliberate planning. Nevertheless, despite the absence of evident premeditation, the killing remained Murder in view of the qualifying circumstance of treachery.
• Authentication of CCTV Footages: The SC agreed with the RTC in appreciating the CCTV footages and admitting them as evidence because they bolstered the testimonies of the witnesses and supported the finding of treachery. As correctly held by the CA, the Rules on Electronic Evidence provides that persons authorized to authenticate the video or CCTV recording is not limited solely to the person who made the recording but also by another competent witness who can testify to its accuracy. Asas was able to establish the origin of the recording and explain how it was transferred to the compact disc and subsequently presented to the trial court. The SC found no reason to contradict such finding.
• Penalty and Civil Liability: Despite the absence of evident premeditation, the killing remained Murder due to treachery. The SC modified the penalty in light of People vs. Jugueta and reverted the penalty to reclusion perpetua in accordance with Article 248 of the Revised Penal Code. Considering that no other aggravating circumstance was present in the killing, the awards of civil indemnity, moral damages, and exemplary damages were reverted to P75,000.00 each. On actual damages, Article 2199 of the Civil Code provides that one is entitled to adequate compensation only for such pecuniary loss suffered by him as he has duly proved. The amounts of P7,286.17 and P100,000.00 as hospital and funeral expenses, respectively, were duly supported by official receipts; the handwritten list of expenses amounting to P36,000.00 shown in Exhibit S was not duly supported by receipts and was properly disregarded. The heirs of the victim were therefore entitled to P107,286.17 as actual damages. Interest at the rate of 6% per annum was imposed on the aggregate amount of the monetary awards computed from finality until full payment.

• Circumstantial Evidence — Circumstantial evidence is proof of collateral facts and circumstances from which the existence of the main fact may be inferred according to reason and common experience. It is sufficient to sustain conviction if (a) there is more than one circumstance; (b) the facts from which the inferences are derived are proven; and (c) the combination of all circumstances is such as to produce a conviction beyond reasonable doubt. The SC applied this rule because the six circumstances formed an unbroken chain pointing to Manansala as the killer.
• Treachery — Treachery is the direct employment of means, methods, or forms in the execution of the crime against persons which tend directly and specially to insure its execution, without risk to the offender arising from the defense which the offended party might make. Its essence is that the attack is deliberate and without warning, done in a swift and unexpected way, affording the hapless, unarmed and unsuspecting victim no chance to resist or escape. The two elements are: (1) at the time of the attack, the victim was not in a position to defend himself; and (2) the accused consciously and deliberately adopted the particular means, methods, or forms of attack employed by him. The SC applied it because Manansala shot the victim from behind while the victim was going upstairs.
• Evident Premeditation — The elements are: (1) a previous decision by the accused to commit the crime; (2) an overt act or acts manifestly indicating that the accused clung to his determination; and (3) a lapse of time between the decision to commit the crime and its actual execution sufficient to allow the accused to reflect upon the consequences of his acts. The essence is that the execution of the criminal act must be preceded by cool thought and reflection upon the resolution to carry out the criminal intent, during the space of time sufficient to arrive at a calm judgment. The SC did not appreciate it because the only basis was a prior confrontation one day before the killing, with no proof of how and when the plan was hatched or the time elapsed before execution.
• Authentication of Electronic Evidence — Under the Rules on Electronic Evidence, the persons authorized to authenticate a video or CCTV recording are not limited solely to the person who made the recording; another competent witness who can testify to its accuracy may authenticate it. The SC applied this rule because Asas established the origin of the CCTV recording and explained how it was transferred to the compact disc presented in court.
• Actual Damages — Article 2199 of the Civil Code entitles a claimant to adequate compensation only for such pecuniary loss suffered by him as he has duly proved. The SC applied this rule by awarding only the hospital and funeral expenses supported by official receipts, and disregarding the handwritten list of expenses without receipts.
• Murder — The elements of Murder are: (a) a person was killed; (b) the accused killed him; (c) the killing was attended by any of the qualifying circumstances mentioned in Article 248 of the Revised Penal Code; and (d) the killing is not parricide or infanticide. The SC applied this framework and found that the killing was Murder because treachery attended it.

• “Circumstantial evidence is sufficient to sustain conviction if (a) there is more than one circumstance; (b) the facts from which the inferences are derived are proven; (c) the combination of all circumstances is such as to produce a conviction beyond reasonable doubt.” — The SC used this standard to affirm Manansala’s identity as the killer through an unbroken chain of circumstantial evidence.
• “The essence of treachery is that the attack is deliberate and without warning, done in a swift and unexpected way, affording the hapless, unarmed and unsuspecting victim no chance to resist or escape.” — The SC quoted this formulation to explain why the killing was qualified by treachery.
• “The essence of evident premeditation is that the execution of the criminal act must be preceded by cool thought and reflection upon the resolution to carry out the criminal intent, during the space of time sufficient to arrive at a calm judgment.” — The SC used this to reject evident premeditation because the prosecution showed no deliberate planning and sufficient lapse of time.
• “Anent the award of actual damages, Article 2199 of the Civil Code provides that "one is entitled to an adequate compensation only for such pecuniary loss suffered by him as he has duly proved."” — The SC applied this rule in awarding only the actual damages supported by official receipts.

• People vs. Evangelio, G.R. No. 181902, August 31, 2011, 656 SCRA 579 — Relied on for the requisites of circumstantial evidence and the unbroken-chain standard.
• People vs. Racal, 817 Phil. 665, 677-678 (2017) — Relied on for the definition and elements of treachery.
• People vs. Kalipayan, G.R. No. 229829, January 22, 2018 — Relied on for the elements of evident premeditation.
• People vs. Abadies, 436 Phil. 978 (2002) — Relied on for the rule that evident premeditation must be based on external acts and must be evident, not merely suspected.
• People vs. Jugueta, 783 Phil. 806 (2016) — Relied on for the modification of the penalty and awards of civil indemnity, moral damages, and exemplary damages.
• People vs. Manzano, G.R. No. 217974, March 5, 2018 — Cited for the rule that an appeal in a criminal case opens the entire case for review.
• People vs. Casemiro, G.R. No. 231122, January 16, 2019 — Cited for the elements of Murder.
• People vs. Lababo, G.R. No. 234651, June 6, 2018 — Cited for the requirement that the prosecution prove the offender killed the victim through treachery or another qualifying circumstance duly alleged in the Information.

• Article 248, Revised Penal Code — Defines Murder and lists qualifying circumstances including treachery and evident premeditation; applied because treachery qualified the killing and the penalty was reclusion perpetua.
• Article 14, paragraph 16, Revised Penal Code — Defines treachery; applied because Manansala shot the victim from behind while the victim was going upstairs, leaving him defenseless.
• Rules on Electronic Evidence — Governs authentication of CCTV or video recordings; applied because Asas, a competent witness, established the recording’s origin and transfer to compact disc, allowing admission.
• Article 2199, Civil Code — Entitles a claimant to adequate compensation only for pecuniary loss duly proved; applied because only the hospital and funeral expenses supported by official receipts were awarded as actual damages, while the handwritten list without receipts was disregarded.