People v. Lacson
REITERATIONFacts
The Antecedents: The accused, Herbito Lacson, along with Lorenzo Mantal and Anacito de la Costi, were charged with murder for the stabbing death of Atty. Jose L. Almario. The information alleged conspiracy, deliberate intent to kill, evident premeditation, treachery, and that the killing was committed for a price or reward, with Lacson taking advantage of the nighttime. Procedural History: Initially, Lacson pleaded guilty and was sentenced to death. However, the Supreme Court remanded the case for a new arraignment and further proceedings due to the lack of a proper record of the arraignment and plea. Lacson's co-accused, Mantal and de la Costi, who did not plead guilty, were convicted with lighter penalties. Upon re-arraignment, Lacson pleaded not guilty, admitting to killing the victim but denying the aggravating circumstances of price or reward, claiming mistaken identity. After trial, the Circuit Criminal Court of Masbate found Lacson guilty of murder with the aggravating circumstances of treachery and commission for a price or reward, sentencing him to death. The case was elevated to the Supreme Court for automatic review. The Appeal: The appellant, Herbito Lacson, appealed his conviction, primarily arguing that he did not kill Atty. Jose L. Almario for a price or reward, that the killing was unpremeditated, and that it was not treacherous. He maintained his defense of mistaken identity, claiming he stabbed the victim because he resembled a person who had previously accosted him. He also challenged the admissibility of his extrajudicial confessions (Exhibits E and G), alleging they were coerced.
Issue(s)
Whether the extrajudicial confessions of the appellant were voluntarily executed and admissible in evidence. Whether the killing of Atty. Jose L. Almario was committed for a price or reward. Whether the killing was attended by evident premeditation. Whether the killing was attended by treachery.
Ruling
The Supreme Court affirmed the judgment of the lower court in toto. The appellant, Herbito Lacson, was found guilty beyond reasonable doubt of the crime of Murder, qualified by evident premeditation and treachery, and aggravated by the commission of the crime for a price or reward, and was sentenced to the supreme penalty of DEATH. He was also ordered to indemnify the heirs of the victim in the amount of P12,000.00 and to pay the costs.
Ratio Decidendi
On the admissibility of extrajudicial confessions (Exhibits E and G): The Court found that the prosecution sufficiently proved the voluntary execution of the appellant's sworn statements. Agent Ilustre V. Cruz testified that the statements were taken in the office of the Provincial Commander, with the Mayor, Municipal Health Officer, and a newspaper correspondent present, and that the accused was informed of his rights. The Municipal Health Officer examined the accused before and after the statements were taken and found no evidence of violence. Municipal Judge Jose Angustia, Sr. testified on the procedure he followed when the accused swore to the statements, including removing his manacles and sending peace officers out of the room, and confirming the accused's affirmation of the statements' truthfulness and his signatures. The appellant's claims of maltreatment were unsubstantiated by details and were not brought to the attention of the judge or the doctor, despite opportunities. The presence of a press representative and the detailed information in the statements, which could only have come from the accused, further supported their spontaneity and voluntariness. The Court concluded that the claims of maltreatment could not be given serious consideration, and the statements were voluntarily executed. On the killing being for a price or reward: The Court found that the killing was for a price or reward, based on the appellant's extrajudicial confession in Exhibit E, which explicitly stated he was promised an undetermined sum of money by Lorenzo Mantal and received P100.00 after the killing. NBI Agent Cruz also testified that Lacson admitted being hired to kill Atty. Almario and was promised a large amount of money. The Court found this evidence negated the appellant's denial and affirmed the finding of this aggravating circumstance. On evident premeditation: The Court held that evident premeditation was sufficiently proven. Lacson's sworn statement (Exhibit G) indicated he was ordered to kill Almario three days prior. He traveled to Masbate, identified the victim's house, and on the day of the killing, followed and waited for Almario. The Court noted that the three days between the formation of the intent to kill and the commission of the crime afforded the accused ample time for reflection and opportunity to desist, but he chose to proceed. The acts of identifying the victim, stalking him, and waiting for the opportunity demonstrated a tenacious will to commit the crime, thus establishing evident premeditation, which qualifies the killing to murder. On treachery: The Court found that the killing was attended by treachery. The attack was sudden and without warning, as described by the appellant himself. The victim was unaware of the impending danger, unarmed, and taken by surprise, rendering him unable to mount a defense or flee. The fact that he was stabbed in the back further confirmed the treacherous nature of the assault, ensuring the execution of the deed without risk to the assailant.
Main Doctrine
The Supreme Court affirmed the conviction for murder, holding that the killing was qualified by evident premeditation and treachery, and aggravated by the commission of the crime for a price or reward. The Court meticulously examined the admissibility of the appellant's extrajudicial confessions, finding them to be voluntarily executed despite claims of coercion, based on the detailed testimonies of law enforcement agents, the presence of a municipal judge and health officer, and the absence of physical injuries. The Court also reiterated that evident premeditation requires proof of the formation of a fixed intention to commit the crime and the subsequent overt acts demonstrating this resolve, while treachery is established when the attack is sudden, unexpected, and without any warning, affording the victim no opportunity to defend himself.