In People v. Mores, the Supreme Court affirmed the conviction of Ramil Mores for murder with multiple attempted murder, solidifying the interpretation of treachery in criminal acts. The court emphasized that throwing a grenade into a crowd constitutes treachery because the victims are given no chance to defend themselves. This ruling underscores the severe consequences for perpetrators of indiscriminate violence and clarifies the application of treachery as a qualifying circumstance for murder, ensuring justice for victims of such heinous acts.

Justice Served: When a Farewell Ball Turns Deadly

The case of People of the Philippines v. Ramil Mores revolves around a tragic incident that occurred on January 24, 1994, during a farewell ball in Barangay Bagumbayan, Roxas, Oriental Mindoro. Ramil Mores was accused of throwing a live hand grenade into the crowd, resulting in the death of Ramie Balasa and injuries to numerous others. The Regional Trial Court (RTC) of Oriental Mindoro found Mores guilty beyond reasonable doubt of the complex crime of Murder with Multiple Attempted Murder. The Court of Appeals (CA) affirmed the RTC’s decision with modifications, leading Mores to appeal to the Supreme Court. This case brings to the forefront critical questions about the elements of treachery, the credibility of witness testimonies, and the legal implications of an accused’s flight from justice.

At the heart of this case is the definition of treachery, a crucial element that elevates a homicide to murder. Article 14, Paragraph 16 of the Revised Penal Code defines treachery as employing means, methods, or forms in the execution of a crime against persons that directly and specially ensure its execution, without risk to the offender arising from the defense the offended party might make. The Supreme Court reiterated that two elements must concur to establish treachery: first, that the victim was not in a position to defend themselves at the time of the attack; and second, that the offender consciously adopted the particular means of attack employed. It is the unexpected and deliberate nature of the attack that defines treachery, leaving the victim helpless and without a chance to resist or escape.

In this context, the Court found that Mores’ act of rolling a grenade onto a crowded dance floor met the criteria for treachery. The unexpected nature of the attack, combined with the indiscriminate impact of a grenade, left the victims with no opportunity to protect themselves. The Court noted that Mores knowingly positioned himself safely away from the grenade’s destructive force, demonstrating a clear intent to ensure the success of his attack without risking his own safety. This calculated action underscored the presence of treachery, affirming the lower courts’ findings.

Appellant Mores contended that the acquittal of his co-accused, Delio Famor, should lead to his own exoneration. However, the Supreme Court clarified that Famor’s acquittal was due to the prosecution’s failure to prove a conspiracy between him and Mores, rather than the acceptance of Famor’s alibi. The trial court found insufficient evidence to establish that Famor was a co-conspirator in the grenade throwing incident, but this did not negate Mores’ own culpability. The Court emphasized that each accused is judged based on the evidence presented against them individually.

Moreover, the Court addressed the credibility of the prosecution witnesses. The defense had questioned the consistency and reliability of their testimonies, but the Supreme Court upheld the lower courts’ assessment, noting that their findings of fact, calibration of testimonies, and assessment of probative weight are accorded high respect. Inconsistencies in minor details do not necessarily discredit a witness, especially when the core of their testimony remains consistent and credible. In this case, the witnesses’ accounts corroborated each other on the key elements of the crime, such as the rolling of the grenade and their proximity to the explosion.

The issue of flight was also considered. Mores argued that his continued presence in the vicinity of Roxas after the incident negated any inference of guilt from his subsequent absence from court proceedings. The Court dismissed this argument, citing established jurisprudence that non-flight does not necessarily equate to innocence. As the Court previously stated in People v. Asilan, “Culprits behave differently and even erratically in externalizing and manifesting their guilt. Some may escape or flee – a circumstance strongly illustrative of guilt – while others may remain in the same vicinity so as to create a semblance of regularity, thereby avoiding suspicion from other members of the community.” Conversely, flight is seen as an evasion of justice, implying a consciousness of guilt.

Analyzing the legal framework, the Court referenced Article 48 of the Revised Penal Code, which addresses complex crimes. When a single act constitutes two or more grave or less grave felonies, the penalty for the most serious crime shall be imposed in its maximum period. In this case, the act of throwing the grenade resulted in murder and multiple attempted murders, making it a complex crime. While Article 248 of the Revised Penal Code prescribes the penalty of reclusion perpetua to death for murder, Republic Act No. 9346 prohibits the imposition of the death penalty, thus the sentence was appropriately modified to reclusion perpetua without eligibility for parole. The Court then ordered the appellant to pay the heirs of the deceased victim the amount of P75,000 as civil indemnity, P50,000 as moral damages and P30,000 as exemplary damages, and for each victim of Attempted Murder, P40,000 as moral damages and P30,000 as exemplary damages. Additionally, interest was imposed on all damages awarded at the legal rate of six percent (6%) per annum from the date of finality of the judgment.

FAQs

What was the key issue in this case?	The primary issue was whether the act of throwing a grenade into a crowd constitutes treachery, thereby qualifying the crime as murder, and whether the appellant’s guilt was proven beyond reasonable doubt. The Court also addressed the effects of an acquittal of a co-accused and the implications of the appellant’s flight from justice.
What is the legal definition of treachery?	Treachery, as defined in Article 14, Paragraph 16 of the Revised Penal Code, involves employing means or methods in the execution of a crime against persons that directly and specially ensure its execution, without risk to the offender arising from the defense the offended party might make. Two elements must concur: the victim was not in a position to defend themselves, and the offender consciously adopted the means of attack.
Why was the co-accused acquitted?	The co-accused, Delio Famor, was acquitted because the prosecution failed to sufficiently prove that he conspired with the appellant. The trial court determined that mere proximity and whispered communications were insufficient to establish conspiracy.
What is a complex crime under Philippine law?	A complex crime, according to Article 48 of the Revised Penal Code, occurs when a single act constitutes two or more grave or less grave felonies. In such cases, the penalty for the most serious crime is imposed, applied in its maximum period.
What was the original penalty imposed by the trial court?	The trial court initially imposed the death penalty on Ramil Mores, but this was modified to reclusion perpetua without eligibility for parole by the Court of Appeals due to the enactment of Republic Act No. 9346, which prohibits the death penalty.
What does ‘flight’ mean in a legal context?	In criminal law, flight refers to evading the course of justice by voluntarily withdrawing oneself in order to avoid arrest, detention, or the continuation of criminal proceedings. Flight is often seen as an indication of guilt.
How did the Supreme Court view the appellant’s flight in this case?	The Supreme Court viewed the appellant’s flight as indicative of guilt, supporting the inference that he was conscious of his wrongdoing and was attempting to evade justice. The Court emphasized that flight is a competent evidence to indicate his guilt, and flight, when unexplained, is a circumstance from which an inference of guilt may be drawn.
What damages were awarded to the victims and their families?	The appellant was ordered to pay the heirs of the deceased victim P75,000 as civil indemnity, P50,000 as moral damages, and P30,000 as exemplary damages. Additionally, each victim of attempted murder was awarded P40,000 as moral damages and P30,000 as exemplary damages.

The Supreme Court’s decision in People v. Mores clarifies the application of treachery in cases involving indiscriminate violence, reinforcing the gravity of such acts and the accountability of the perpetrators. This ruling serves as a stern warning against actions that endanger public safety and underscores the judiciary’s commitment to upholding justice and protecting the rights of victims.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: PEOPLE OF THE PHILIPPINES, VS. RAMIL MORES, G.R. No. 189846, June 26, 2013