People v. Esteban y Molina and Camaya y Rocha
REITERATIONFacts
The Antecedents: Antonio Maravilla and his common-law wife, Loreta Alega (Lulu), went to collect a balance of P47 from Luis Camaya regarding a compromise settlement for the killing of Lulu's husband, in which Camaya, Mariano Esteban, and Tomas Ablola were implicated. Camaya stated Esteban would advance the payment. Later, Maravilla went to Esteban to collect the balance; Esteban promised to pay P20 the next day, and Maravilla warned him about the provisional dismissal of the criminal case. Maravilla then joined a drinking spree in the yard of Maria Pascua. At around 11:00 PM, successive gunshots were fired at the group. Maravilla saw Esteban and Ablola (Mati) leaving the scene, with Mati handing an automatic rifle to his companion. Maravilla realized he was wounded in the shoulder and below the nape. Maria Pascua, sleeping inside the house, was fatally wounded by a bullet. Police found empty shells and a slug. Maravilla collapsed on the street and, in a dying declaration to Patrolman Cayetano Cedilla, identified Esteban and Ablola as his assailants. Maravilla also identified Esteban at the hospital. A paraffin test on Esteban's hands was positive for nitrate specks. Later, Maravilla identified photographs of Camaya and Ablola as companions of Esteban on the night of the shooting. Procedural History: Two informations were filed against Esteban and two unidentified persons for murder (Maria Pascua) and frustrated murder (Antonio Maravilla). Camaya was later included as an accused after Maravilla identified him. The cases were tried jointly. The trial court convicted Esteban and Camaya of murder and frustrated murder. The Petition: Appellants Mariano Esteban and Luis Camaya appealed their convictions.
Issue(s)
Whether the guilt of Luis Camaya for murder and frustrated murder was proven beyond reasonable doubt. Whether Mariano Esteban was sufficiently identified as one of the assailants. Whether the killing of Maria Pascua constituted murder qualified by treachery and aggravated by dwelling. Whether Mariano Esteban is liable for frustrated murder for the assault on Antonio Maravilla. Whether the penalties and indemnities imposed by the trial court were correct.
Ruling
The Court acquitted Luis Camaya due to reasonable doubt. The conviction of Mariano Esteban for murder was affirmed, with the indemnity increased and the death penalty commuted to reclusion perpetua. For frustrated murder, Esteban was sentenced to an indeterminate penalty. The Court modified the penalties and indemnities imposed by the trial court.
Ratio Decidendi
On the guilt of Luis Camaya: The Court found the evidence against Camaya insufficient to establish his guilt beyond reasonable doubt. The sole eyewitness, Maravilla, did not implicate Camaya in his initial statements (res gestae declarations) made immediately after the shooting. Camaya was only implicated more than six months later, which the Court considered a belated denunciation lacking spontaneity and bearing the earmarks of an afterthought or frame-up. The Court invoked the principle that it is better that ten guilty persons go unpunished than that one innocent person be convicted. Therefore, Camaya was acquitted. On the identification of Mariano Esteban: The Court found that Mariano Esteban was sufficiently identified by Antonio Maravilla as one of the three assailants. Maravilla identified Esteban in his res gestae declarations made shortly after the shooting, both at the scene and at the hospital. The paraffin test on Esteban's hands, which was positive for nitrate specks, further corroborated the finding that he had recently fired a gun. Esteban's alibi was deemed flimsy and not credible. His silence when confronted at the hospital also contributed to the evidence against him. On the killing of Maria Pascua: The Court ruled that the killing of Maria Pascua, who was asleep, was murder qualified by treachery. Nocturnity was absorbed by treachery. Dwelling was appreciated as an aggravating circumstance. The Court also applied Article 4 of the Revised Penal Code, stating that a person committing a felony is criminally liable for the wrongful act done, even if it be different from that which he intended (aberratio ictus or mistake as to victim). Thus, Esteban was liable for murder even if his intention was to kill Maravilla and Maria Pascua was an unintended victim. On the frustrated murder of Antonio Maravilla: The Court found Esteban guilty of frustrated murder for the assault on Maravilla. The injuries sustained by Maravilla were severe, causing paralysis and requiring extensive hospitalization. Without medical intervention, Maravilla would have died. The Court noted that the trial court erred in imposing a straight penalty and that Esteban was entitled to an indeterminate sentence. On Penalties and Indemnities: The Court affirmed the conviction for murder but commuted the death penalty to reclusion perpetua due to lack of necessary votes. The indemnity to Maria Pascua's heirs was increased to P12,000. For frustrated murder, Esteban was sentenced to an indeterminate penalty of ten (10) years of prision mayor as minimum to fourteen (14) years of reclusion temporal as maximum, and ordered to pay Maravilla an indemnity of P10,000.
Main Doctrine
The Court affirmed the conviction of Mariano Esteban for murder and frustrated murder, modifying the penalties and indemnities. Luis Camaya was acquitted due to reasonable doubt. The Court reiterated that aberratio ictus (mistake as to victim) does not absolve the offender from liability for the death of the unintended victim, and that dwelling is an aggravating circumstance in murder.