People v. Maranan
REITERATIONFacts
The Antecedents: The accused, Catalino Maranan, was indicted for Murder. The prosecution presented evidence that on April 22, 1972, at around 8:00 PM, the appellant disrupted a game of 'cara y cruz' by grabbing the coins. When Federico Lirio told him they were not adversaries, the appellant became angry and uttered bad words. Lirio and Rolando Alcantara left to ply their route. Upon their return between 11:00 PM and 12:00 AM, while Alcantara was driving Lirio's jeepney with Lirio and Alfonso Santos ('Jun') in the front seat, the appellant, from a distance of about four meters, fired twice with a .22 caliber gun. Alfonso Santos was hit on the forehead and died, while Lorenzo Francisco ('Enchong'), a passenger in the rear, was hit on the knee. The autopsy revealed the cause of death was a gunshot wound to the forehead, penetrating the brain. Procedural History: The former Court of First Instance of Rizal, Branch XXXV, found the accused guilty of Murder and sentenced him to reclusion perpetua. The accused appealed. The Petition: The accused appealed the decision, attributing errors to the trial court in convicting him of Murder based on allegedly contradictory testimonies and in considering flight as a basis for conviction without direct or corroborative evidence.
Issue(s)
Whether the trial court erred in convicting the accused of Murder by giving credence to allegedly contradictory and irreconcilable testimonies of prosecution witnesses, and in appreciating and making flight as a basis for conviction despite the absence of direct or corroborative evidence showing guilt. Whether the conviction for Murder was proper, considering the presence of treachery and the unintended victim.
Ruling
The judgment appealed from is affirmed in toto. The accused-appellant Catalino Maranan is found guilty beyond reasonable doubt of the crime of Murder, qualified by treachery, and sentenced to reclusion perpetua.
Ratio Decidendi
On the alleged contradictory and irreconcilable testimonies and the appreciation of flight: The Court found that the prosecution witnesses positively identified the appellant. Minor inconsistencies did not destroy their veracity. Flight was not the sole basis for conviction but an additional circumstance indicative of guilt. The appellant avoided arrest for four years, and flight is admissible evidence against the accused. On the conviction for Murder and the presence of treachery: The Court found proof beyond reasonable doubt of the appellant's guilt. The crime was qualified by treachery. The fact that Alfonso Santos was killed instead of the intended victim does not exonerate the appellant. Treachery can be considered even if the victim was not the intended one, provided neither person could defend themselves or become aware of the attack.
Main Doctrine
The qualifying circumstance of treachery may be properly considered even when the victim of the attack was not the one whom the defendant intended to kill, if it appears from the evidence that neither of the two persons could in any manner put up defense against the attack or become aware of it. Flight is a circumstance admissible in evidence against an accused, and if not explained consistently with innocence, tends to show guilt.