### Facts:
On April 11, 2006, in Sto. Tomas, La Union, Philippines, Rogelio Ramos and Marissa Intero Ramos were accused of murdering Ronald A. Abacco using a bladed weapon, with the aggravating circumstances of treachery and abuse of superior strength. After pleading not guilty, the trial ensued with opposing versions from the prosecution and defense.
**Prosecution’s Claims:** Rogelio initially threw stones at Ramon Ramos’s house, where victim Abacco was staying. Abacco, unarmed, approached the Ramoses to talk. Upon opening their gate, Rogelio attacked Abacco with a samurai sword, dragged him into their yard, and, with Marissa’s encouragement, hacked him several times to death.
**Defense’s Version:** The Ramoses claimed self-defense and alibi. Rogelio stated Abacco attacked him first, prompting him to retaliate with a samurai sword in self-defense. Marissa claimed she was not at the scene but was seeking help from barangay officials.
The Regional Trial Court found the couple guilty, a decision later affirmed by the Court of Appeals with modifications including additional exemplary damages awarded to the victim’s heirs. The appellants then[ appealed to the Supreme Court.
### Issues:
1. Whether the invocation of self-defense by Rogelio and denial and alibi by Marissa were tenable.
2. The credibility of the prosecution witnesses and the evaluation of their testimonies.
3. Whether the element of treachery was present to qualify the killing as murder.
4. The proper penalties and damages due to the heirs of the victim.
### Court’s Decision:
The Supreme Court dismissed the appeal, affirming the lower courts’ decisions with modifications regarding damages amounts.
1. **Rogelio’s Self-defense:** The Court concluded that Rogelio failed to prove unlawful aggression from Abacco, the necessity of his means of defense, or lack of sufficient provocation. The severity of Abacco’s wounds indicated an intent to kill rather than self-defense.
2. **Marissa’s Alibi:** Marissa’s claims were undermined by the proximity of her location to the crime scene and the possibility of her presence at the time of the crime. Eyewitness testimony positively identified her participation.
3. **Witness Credibility:** The Court upheld the credibility of the prosecution’s witnesses, dismissing the appellants’ claims of motivations for false testimony due to a prior dispute.
4. **Presence of Treachery:** The Court agreed that the attack was treacherous as it ensured execution without risk to the attackers, qualifying the crime as murder.
5. **Penalties and Damages:** Affirmed reclusion perpetua for both appellants, increased exemplary damages to P30,000.00, awarded actual damages of P40,000.00, and imposed a legal interest rate on all monetary awards.
### Doctrine:
The decision highlights the principles regarding the evaluation of self-defense claims, witness credibility assessment, and the qualifications for murder, particularly focusing on the concept of treachery.
### Class Notes:
– **Self-defense:** Requires proof of unlawful aggression, necessity of means used to repel it, and lack of sufficient provocation by the person defending himself.
– **Alibi and Denial:** Must establish physical impossibility of presence at the crime scene and is generally weak against positive identification.
– **Treachery (Alevosia):** Involves employing means in the execution of a crime that directly and specially ensures its execution without risk to the aggressor arising from any defensive action the victim might take (Revised Penal Code, Art. 14, par. 16(2)).
– **Murder vs. Homicide:** Distinguished by qualifying circumstances such as treachery (Revised Penal Code, Art. 248).
– **Damages in Criminal Cases:** Include civil indemnity, moral damages, exemplary damages, actual damages, and, in applicable cases, legal interest on these amounts.
### Historical Background:
The Supreme Court’s decision is consistent with its long-standing jurisprudence on murder cases, emphasizing strict requirements for proving self-defense claims and the significant role of eyewitness testimony in criminal proceedings.
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