FACTS:

Accused-appellant Eddie Manansala 

On November 2, 2013, at around 8 o’clock in the evening, brothers Edward and Elmer Reyes were in front of their rented apartment owned by the victim Armando Ramos who also resides there, when suddenly they heard a gunshot inside the house. Edward then saw Manansala facing towards the direction of the stairs and holding a gun aimed upwards. Thereafter, Manansala hurriedly left. 

Edward also saw Ramos fall from the stairs with blood oozing from his left chest. Ramos subsequently died. 

During trial, the closed-circuit television (CCTV) footages of the crime scene were presented in court where a man appearing to be Manansala was seen entering the house while armed with a gun and proceeding upstairs. The man then aimed his gun, shot the victim and immediately thereafter left the house.

The victim’s son, Asas testified that he was the one who transferred the video footages from the barangay-owned CCTV that was located outside their house to the compact disc that was submitted in court as evidence. When the footage was played in court and the enlarged screenshot was presented, he identified said person as Manansala and the perpetrator of the crime.

The prosecution also presented the testimony of Barangay Kagawad Piojo who confirmed the location of the CCTV. 

Manansala was found guilty beyond reasonable doubt of the crime of Murder.

The RTC relied heavily on the accounts of the eyewitnesses pointing to Manansala as the author of the crime, especially since their accounts were corroborated by the CCTV footages.

Upon review, the CA sustained the finding of the RTC that the prosecution was able to establish all the elements of the crime of Murder.

Undeterred, Manansala filed his appeal.

ISSUE:

Whether or not the accused-appellant is guilty of the crime charged.

RULING:

The instant appeal is dismissed.

We are in agreement with the Office of the Solicitor General in its brief, as affirmed by the CA, that the prosecution was able to establish that Manansala was the author of the crime of murder based on the following circumstantial evidence:

1. Upon hearing the gunshot, Edward turned around and saw appellant holding a gun.

2. When Edward saw appellant, the latter was facing the stairs of the victim’s house where he had his gun aimed towards the stairs.

3. After Edward saw appellant running towards Lico Street, the former went back to the place where the gunshot was heard and there he saw the victim face down on the ground bloodied and unconscious. Blood was oozing from the victim’s left chest.

4. Mananquil, on the other hand, after hearing the gunshot turned to his right and saw appellant coming out from the house of the victim.

5. When appellant was no longer in the vicinity of the shooting, Mananquil went back to the victim’s house. There he saw the victim lying down.

6. The CCTV and its printouts corroborating the testimonies of Edward and Mananquil.

Jurisprudence dictates that the elements of murder are as follows: 

(a) that a person was killed; 

(b) that the accused killed him; 

(c) that the killing was attended by any of the qualifying circumstances mentioned in Article 248; and 

(d) that the killing is not parricide or infanticide.

Thus, for the charge of Murder to prosper, the prosecution must prove beyond reasonable doubt that: 

(1) the offender killed the victim, 

(2) through treachery, or by any of the other five qualifying circumstances, duly alleged in the Information.

Paragraph 16, Article 14 of the RPC 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. In order for treachery to be properly appreciated, two elements must be present:

(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.

These elements are present in this case as testified to by the prosecution witnesses and corroborated by the CCTV footages.

Manansala stealthily entered the house of the victim and shot him while he was going upstairs. 

Incidentally, treachery was also proven by the CCTV footages presented in court and testified on by witness Asas.

This Court agrees with the CA that the pieces of circumstantial evidence sufficiently support the finding that Manansala was the one who killed the victim. It is an elementary rule in criminal law that absence of direct evidence. 

This Court also agrees with the RTC in appreciating the CCTV footages and admitting the same as evidence because they bolstered the testimonies of the witnesses and supported the finding of treachery in the case at bar. 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.

In the case at bar, 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. 

Hence, this Court finds no reason to contradict such finding.