G.R. No. L-7900, October 18, 1912
THE UNITED STATES, plaintiff-appellee, vs. NUMERIANO RAMOS, defendant-appellant.

FACTS

On the night of June 16, 1910, in Balayan, Batangas, Pedro Ramirez heard cries of “murder” and found Severino de Chaves wounded on the ground. Chaves identified his godfather, Numeriano Ramos, as his assailant and begged to be taken to the municipal building, where he later died from his abdominal wound. Meanwhile, police officers Mauricio Aesquivel and Teofilo Javier saw Ramos fleeing with a bloody dagger and a blood-stained hand. Ramos threatened the officers and escaped into a nipa palm grove. He remained at large until his arrest in October 1910. Before his death, Chaves repeatedly named Ramos as his attacker in statements to his wife, the doctor, the justice of the peace, and the police officers. The justice of the peace took Chaves’s sworn ante-mortem declaration. Ramos was charged with murder, convicted by the trial court, and sentenced to reclusion temporal.

ISSUE

Whether the trial court erred in convicting the defendant of homicide based on the dying declarations of the victim and circumstantial evidence.

RULING

No, the trial court did not err. The Supreme Court affirmed the conviction but modified the crime from murder to homicide. The dying declarations of Severino de Chaves, repeatedly naming Numeriano Ramos as his assailant and made under a consciousness of impending death, were admissible as evidence. These declarations, corroborated by circumstantial evidence (Ramos fleeing with a bloody weapon, his blood-stained hand, and his flight and prolonged absence), established Ramos’s guilt beyond reasonable doubt as the perpetrator of the fatal wound. However, the record did not prove any qualifying circumstances to elevate the crime to murder. The Court also held that the defendant is responsible for the consequences of his violent act, regardless of the victim’s particular physical condition or temperament that may have contributed to the death. The penalty imposed by the trial court was affirmed.