People v. Camay
REITERATIONFacts
The Antecedents: Rosario Suan, her son Dominador Sollano, Natividad Noynay, and Zosimo Mina traveled from Medellin, Cebu to San Isidro, Leyte, to purchase a sailboat. After purchasing the sailboat for P450 and making preparations for their voyage to Masbate, they hired two local men and Cipriano Camay as helmsman. On August 3, 1948, they sailed from San Isidro, Leyte, stopping to buy corn, and proceeded towards Masbate. Procedural History: Cipriano Camay was accused before the Court of First Instance of Cebu of multiple murder for the deaths of Rosario Suan, Dominador Sollano, and Zosimo Mina. He was found guilty and sentenced to indeterminate penalties for each death, to be served successively, and to indemnify the families. He appealed the decision. The Appeal: The defendant-appellant, Cipriano Camay, appealed his conviction. His primary argument was that he did not participate in the killings, attributing the crime to the other members of the crew who remained at large. He claimed he was afraid to intervene or report the incident due to fear of the assailants. The prosecution presented Natividad Noynay as the sole eyewitness and pointed to the possession of the victims' belongings by the appellant as evidence of guilt.
Issue(s)
Whether the crime committed was multiple murder qualified by treachery. Whether the penalty imposed by the trial court was correct. Whether the indemnity awarded was proper.
Ruling
The Supreme Court affirmed the conviction for multiple murder but modified the penalty. The Court imposed the penalty of reclusion perpetua for each of the three deceased, to be served successively but not to exceed forty years. The indemnity for each victim was increased to P6,000, without subsidiary imprisonment in case of insolvency, and the appellant was ordered to pay the costs.
Ratio Decidendi
On Issue 1: The Court ruled that the crime committed was multiple murder qualified by treachery. The sole eyewitness, Natividad Noynay, testified that while the deceased were stabbed in the abdomen, the attacks were part of a concerted action by three armed individuals against unsuspecting victims in the early morning hours. This surprise attack, where the victims had no opportunity to defend themselves, constituted treachery. The Court held that other circumstances, such as abuse of superior strength and nighttime, were absorbed by the qualifying circumstance of treachery. Premeditation was not charged nor proven. The generic aggravating circumstance of uninhabited place was considered but did not lead to the death penalty due to insufficient votes. On Issue 2: The Court modified the penalty imposed by the trial court. While the trial court imposed seventeen (17) years, four (4) months and one (1) day of reclusion temporal, as minimum, to reclusion perpetua, as maximum, for each victim, the Supreme Court imposed reclusion perpetua for each of the three deceased. This penalty was to be served successively, with the total period not to exceed forty years, in accordance with the rules on successive service of penalties. The Court noted that the death penalty was not imposed due to a lack of sufficient votes, a procedural consideration in en banc decisions. On Issue 3: The Court increased the indemnity awarded to the heirs of each deceased. The trial court awarded P5,000 for each victim, but the Supreme Court increased this to P6,000 per victim. The Court also specified that there would be no subsidiary imprisonment in case of insolvency, which is standard for crimes punishable by reclusion perpetua.
Main Doctrine
The crime of multiple murder was established, with treachery identified as the qualifying circumstance. Treachery exists when the attack is performed with the attendance of treachery, meaning that the offended party was not given the chance to defend himself. The Court found that the surprise attack by three assailants at 3 o'clock in the morning against unsuspecting victims, who were killed one by one, constituted treachery, absorbing other aggravating circumstances such as abuse of superior strength and nighttime.