People v. Traya
REITERATIONFacts
The Antecedents: Appellant Leopoldo Traya, along with co-accused Octavio Traya, Wenceslao Verterra, and Antonio Natulla Cinco, were charged with murder for the fatal shooting of Dr. Pedro Alvero, the Vice-Mayor of Abuyog, Leyte. The prosecution alleged the commission of the crime with treachery and evident premeditation, and the aggravating circumstances of grave abuse of superior strength and disregard of the respect due the victim's rank. Procedural History: The trial court found insufficient evidence for the qualifying circumstances of treachery and evident premeditation, convicting only for the lesser offense of homicide. Leopoldo Traya was sentenced to six (6) years and four (4) months of prision mayor to thirteen (13) years and ten (10) months of reclusion temporal. Wenceslao Verterra received nineteen (19) years and eight (8) months of reclusion temporal. Octavio Traya was acquitted. Antonio Natulla Cinco remained at large. The Petition: Leopoldo Traya appealed to the Court of Appeals. The appellate court, disagreeing with the trial court, found that the offense was qualified by treachery and that the penalty should be reclusion perpetua. Consequently, in compliance with the Rules, the Court of Appeals refrained from rendering judgment and certified the case to the Supreme Court.
Issue(s)
Whether the Court of Appeals, upon finding that the proper penalty should be reclusion perpetua instead of the lesser penalty imposed by the trial court, should refrain from rendering judgment and forthwith certify the case to the Supreme Court.
Ruling
The Supreme Court remanded the case to the Court of Appeals for rendition of the proper judgment, in accordance with the established procedure for cases where the appellate court finds that the penalty of death or reclusion perpetua should be imposed.
Ratio Decidendi
On Issue 1: The Supreme Court examined the established procedure under Section 12, Rule 124 of the Rules of Court, which governs the Court of Appeals' (CA) actions when it believes a penalty of death or reclusion perpetua should be imposed in a criminal case. This rule previously mandated that the CA simply refrain from entering judgment and immediately certify the case to the Supreme Court for final determination. However, this established procedure was significantly updated by the Court's ruling in People vs. Daniel, L-40330, promulgated on November 20, 1978. In Daniel, the Supreme Court issued a new directive requiring the Court of Appeals to first "render judgment expressly and explicitly imposing the penalty of either death or reclusion perpetua as the circumstances warrant," before refraining from "entering judgment." Following this, the CA is then to "forthwith certify the case and elevate the entire record thereof to this Court for review." Therefore, applying this new ruling, the Supreme Court determined that the instant case must be remanded to the Court of Appeals for proper compliance with the updated procedural mandate.
Main Doctrine
The Court of Appeals, when of the opinion that the penalty of death or reclusion perpetua should be imposed in a case where the trial court imposed a lesser penalty, shall refrain from entering judgment and shall certify the case to the Supreme Court for final determination.