People v. Centeno
REITERATIONFacts
The Antecedents: Francisco Centeno, Juan Centeno alias Totok, and Manuel Centeno alias Iyao were charged with Murder in the Court of First Instance of Iloilo. The trial court found them guilty of simple homicide, not murder, as treachery and evident premeditation were not found to be present. They were sentenced to imprisonment and ordered to indemnify the heirs of the deceased Nestor Asistido. Procedural History: On appeal, the Court of Appeals expressed the opinion that the crime committed was Murder, with treachery and evident premeditation present, and that the penalty could be life imprisonment or death. However, instead of imposing a penalty, the Court of Appeals certified the case to the Supreme Court for final determination, citing Section 34 of the Judiciary Act and Section 12 of Rule 124 of the Rules of Court. The Petition: The case was before the Supreme Court for final determination of the proper penalty.
Issue(s)
Whether the Court of Appeals erred in certifying the case to the Supreme Court instead of rendering judgment, considering the procedure outlined in People v. Daniel. Whether the ruling in People v. Daniel requiring the Court of Appeals to expressly impose the death penalty or reclusion perpetua and then certify the case to the Supreme Court is the correct procedure, especially in light of Section 17 of the Judiciary Act and Section 12 of Rule 124.
Ruling
The Supreme Court returned the case to the Court of Appeals for proper action, directing the latter to determine for itself the proper penalty in accordance with the ruling in People v. Daniel.
Ratio Decidendi
On the procedure for the Court of Appeals in cases involving the death penalty or life imprisonment: The Supreme Court reiterated its ruling in People v. Daniel, G.R. No. L-40330, November 20, 1978. This ruling mandates that if the Court of Appeals is of the opinion that the penalty of death or reclusion perpetua should be imposed in a criminal case appealed to it where the penalty imposed by the trial court is less than reclusion perpetua, the said Court should render judgment expressly and explicitly imposing the penalty of either death or reclusion perpetua, refrain from entering judgment, and forthwith certify the case and elevate the entire record thereof to the Supreme Court for review. The Court acknowledged that this procedure was established to ensure that cases involving the highest penalties are reviewed by the Supreme Court as mandated by the Constitution and the Judiciary Act. The Supreme Court refrained from passing on the correctness of the Court of Appeals' assessment of the evidence and found the Court of Appeals' analysis to be sufficiently thorough and exhaustive. Therefore, in accordance with the Daniel ruling, the case was returned to the Court of Appeals for it to determine for itself the proper penalty based on its own analysis of the evidence and to proceed with the certification to the Supreme Court if warranted. On the interpretation of Section 17 of the Judiciary Act and Section 12 of Rule 124: The Court noted the ongoing discussion and differing views regarding the interpretation of these provisions. While the ponente expressed a personal view favoring the old practice of simply certifying the case after analysis, the controlling effect of the Daniel doctrine was conceded. The Court emphasized that the constitutional provision granting the Supreme Court exclusive jurisdiction to review cases where the penalty imposed is death or life imprisonment is paramount. The interpretation of the Judiciary Act and the Rules of Court must conform to this constitutional mandate. The Court also touched upon the potential constitutional infirmity of viewing Section 17 of the Judiciary Act as an enlargement of the Supreme Court's jurisdiction, suggesting it could be viewed as a limitation on the Court of Appeals' jurisdiction, thereby saving it from constitutional challenge.
Main Doctrine
The Court of Appeals, when of the opinion that the penalty of death or reclusion perpetua should be imposed in a case appealed to it where the penalty imposed by the trial court is less than reclusion perpetua, should render judgment expressly imposing the penalty of either death or reclusion perpetua, refrain from entering judgment, and forthwith certify the case and elevate the entire record to the Supreme Court for review, in accordance with the ruling in People v. Daniel.