Title: People v.

Ringor Name of Digester: Sabayle

G.R. No 123918 Date: December 9, 1999 Ponente: Purisima, J

Subject / Syllabus Topic: Prospectivity

Petitioner: People of the Philippines Respondent: Augusto

Loreto Ringor, Jr.
Doctrine (if applicable):

Recit Summary:

Facts:
On June 23, 1994 at around 6:00 in the evening, Fely Batanes, a waitress at the People’s
Restaurant, saw Ringor and his two companions enter the restaurant. After seating themselves,
they ordered a bottle of gin. Minutes later, appellant approached one of the tables where Florida,
the restaurant’s cook, was drinking beer. Without any warning, Ringor pulled Florida’s hair and
poked a knife on the latter’s throat. Florida stood up and pleaded not to harm him. Thereafter,
they left the restaurant but went back holding a gun, entered the kitchen of the restaurant,
stealthily approached Florida from behind and fired six successive shots at Florida which caused
his death. Ringor was then arrested and caught in his possession was an unlicensed firearm. He
admitted shooting the victim but theorized that he acted in self-defense. However, the appellant
failed to prove the element of unlawful aggression. Prosecution witness Fely Batanes was firm in
her declaration that the victim was in the kitchen unarmed when Ringor shot him. The victim
had no bolo as what Ringor was claiming and likewise, he was not manifesting any aggressive act
which could have imperiled Ringor’s safety and well-being. Thus, Ringor was found guilty of
murder and was sentenced to death. He was also found guilty of a separate charge of illegal
possession of firearms with a sentence of 17 to 20 years.
Issue/s: Ruling:
Is RA 8294 (which took effect on July 6, 1997) applicable to the No.
accused (crime occurred on June 23, 1994)?
Holding:
At the time of the commission of the crime, the use of an unlicensed firearm in taking the life of
another was not yet an aggravating circumstance in homicide or murder. If this will be applied,
the penalty of death will be imposed to Ringor. Thus, RA 8294 cannot be applied as it is
unfavorable to the accused, lest it becomes an ex post facto law.
Separate Opinions:

Notes:
RA 8294 - AN ACT AMENDING THE PROVISIONS OF PRESIDENTIAL DECREE NO.
1866, AS AMENDED, ENTITLED “CODIFYING THE LAWS ON
ILLEGAL/UNLAWFUL POSSESSION, MANUFACTURE, DEALING IN, ACQUISITION
OR DISPOSITION OF FIREARMS, AMMUNITION OR EXPLOSIVES OR
INSTRUMENTS USED IN THE MANUFACTURE OF FIREARMS, AMMUNITION OR
EXPLOSIVES, AND IMPOSING STIFFER PENALTIES FOR CERTAIN VIOLATIONS
THEREOF, AND FOR RELEVANT PURPOSES”