People v. Plateros
REITERATIONFacts
The Antecedents: Before midnight of July 30, 1972, Jacinto Piquero and Fernando Anora, pedicab drivers, entered Inday's Kitchenette. They joined other pedicab drivers, including Pedro Candel, at a table. Tomas Metucua, a college student and rival of Warlito Plateros for the affection of Estrella Silmaro, the cashier, was also present. Plateros and Murillo Lahoy were also at the kitchenette. As Candel, Metucua, Piquero, and Anora left the kitchenette to go to their pedicab, Lahoy and Plateros emerged. Lahoy stabbed Candel twice, and Plateros also stabbed Candel. Candel fell and died later that morning due to irreversible shock from the stab wounds. The autopsy revealed three fatal stab wounds. The prosecution alleged that the killing was motivated by Plateros' jealousy over Metucua and that Lahoy acted as Plateros' co-conspirator. Procedural History: The Court of First Instance of Bohol found Plateros and Lahoy guilty of murder and sentenced them to reclusion perpetua. Lahoy was also convicted of attempted murder in a separate case (Criminal Case No. 567) and sentenced to an indeterminate penalty. Lahoy appealed both convictions. The Court of Appeals acquitted Lahoy in the attempted murder case. Plateros and Lahoy appealed their murder conviction to the Supreme Court. The Petition: Appellants Plateros and Lahoy appealed their conviction for murder, contending that their guilt was not proven beyond reasonable doubt, that their denials were disregarded, and that there was no proven motive.
Issue(s)
Whether the Court of Appeals' acquittal of Lahoy in the attempted murder case should be set aside for lack of appellate jurisdiction. Whether the guilt of appellants Plateros and Lahoy for murder was proven beyond reasonable doubt. Whether treachery was present, qualifying the killing to murder. Whether the killing was a case of aberratio ictus or error en la persona.
Ruling
The judgment of the trial court finding Warlito Plateros and Murillo Lahoy guilty of murder is affirmed. The acquittal of Lahoy in the attempted murder case by the Court of Appeals is not disturbed. Appellants are sentenced to reclusion perpetua and ordered to pay solidarity to the heirs of Pedro Candel an indemnity of P12,000.
Ratio Decidendi
On the jurisdiction of the Court of Appeals in the attempted murder case: The Court held that while Section 17(l) of the Judiciary Law generally requires cases arising from the same occurrence or committed on the same occasion as a capital offense to be certified to the Supreme Court, an exception exists. This exception applies when deciding the lesser offense by the Court of Appeals would not create a conflict with the decision of the Supreme Court in the more serious offense. In this case, the victims in the murder case (Pedro Candel) and the attempted murder case (Tomas Metucua) were different. Therefore, Lahoy's acquittal in the attempted murder case would not affect the determination of his guilt in the murder case, and the Court declined to disturb the Court of Appeals' decision, following the precedent in People v. Cariño. On the guilt of appellants Plateros and Lahoy for murder: The Court found that the positive and unequivocal declarations of eyewitnesses Fernando Anora and Jacinto Piquero, who identified Plateros and Lahoy as the perpetrators, prevailed over the feeble denials and alibi of the appellants. The trial court meticulously analyzed the testimonies and found the prosecution witnesses credible and the defense flimsy. The Court affirmed the trial court's finding that the appellants' guilt was proven beyond reasonable doubt. On treachery and the qualification to murder: The Court ruled that the killing was properly categorized as murder due to treachery. The appellants waited for the victims to leave the kitchenette and launched a surprise, deliberate, and unexpected attack, indicating an intention to commit the crime without risk to themselves. This sudden and unexpected assault is a characteristic manifestation of treachery (alevosia), as defined in Article 14(16) of the Revised Penal Code. On aberratio ictus or error en la persona: The Court explained that the killing of Pedro Candel, instead of Tomas Metucua, was likely a case of aberratio ictus (mistake in the blow) or error en la persona (mistake in the identity of the victim). Given that the stabbing occurred at night and the assailants were allegedly inebriated, they mistakenly assumed that Candel, the pedicab driver in the sidecar, was Metucua, the intended victim, and that Metucua, on the driver's seat, was someone else. The Court noted that Plateros was jealous of Metucua, providing a motive for targeting him, and Lahoy acted as a co-conspirator.
Main Doctrine
Where an offense not punishable by death or reclusion perpetua arose from the same occurrence or was committed on the same occasion as an offense punishable by death or reclusion perpetua, and the Court of Appeals decides the former case without conflict with the latter case pending in the Supreme Court, the former case need not be elevated to the Supreme Court, applying the exception to the rule on avoiding conflicting decisions.