People v. Mendez
REITERATIONFacts
1. The Antecedents: This case involves a double murder. Geroncio Mendez and Abing Bolioc were convicted of murdering Roberto Boiser, receiving a death sentence and ordered to indemnify his heirs. They were also convicted of the murder of Angel Ibañez, sentenced to reclusion perpetua, and ordered to indemnify his heirs. The underlying dispute appears to stem from prior complaints and counter-charges related to a basketball game incident and subsequent altercations. 2. Procedural History: The accused, Geroncio Mendez and Abing Bolioc, were charged with double murder in a single information. The trial court convicted Mendez and Bolioc of the murder of Roberto Boiser, sentencing them to death, and also convicted them of the murder of Angel Ibañez, sentencing them to reclusion perpetua. Other co-accused were either at large, died during trial, or were acquitted. The judgment for the Ibañez murder became final and executory, and is not under review. This review is automatic due to the death penalty imposed on Mendez and Bolioc for Boiser's murder. The parents of Abing Bolioc moved for a new trial based on his alleged minority status, which was denied by the trial court. 3. The Petition: This is an automatic review of the death penalty imposed on Geroncio Mendez and Abing Bolioc for the murder of Roberto Boiser. The defense contends that the trial court erred in convicting Geroncio Mendez and imposing the death penalty, arguing for reasonable doubt. The defense also raised the issue of Abing Bolioc's age at the time of the offense, claiming he was a minor and thus entitled to a suspended sentence, though the trial court denied this. The Supreme Court, while affirming the conviction for murder qualified by evident premeditation and treachery, commuted the death penalty for Geroncio Mendez to reclusion perpetua due to lack of necessary votes and reduced the penalty for Abing Bolioc based on his age at the time of the offense.
Issue(s)
Whether the trial court erred in convicting Geroncio Mendez of murder and imposing a death penalty, and in not imposing a lighter penalty on grounds of reasonable doubt regarding the killing of Roberto Boiser. Whether Abing Bolioc, as a member of the cultural minority and allegedly a minor at the time of the offense, is entitled to a suspended sentence or a reduction of penalty for the killing of Roberto Boiser. Whether the killing of Roberto Boiser was murder qualified by evident premeditation and aggravated by treachery. Whether the killing of Angel Ibañez was committed by Geroncio Mendez on the spur of the moment, and the implications for conspiracy. Whether the testimonies of Celestino Mendez can prevail over the positive identification made by prosecution witnesses.
Ruling
The judgment of the trial court is affirmed with the modification that the death penalty imposed on Geroncio Mendez is commuted to reclusion perpetua, and the penalty on Abing Bolioc is reduced. Costs de oficio.
Ratio Decidendi
On the conviction of Geroncio Mendez for murder: The contention that the trial court erred in convicting Geroncio Mendez of murder and imposing a death penalty, and in not imposing a lighter penalty due to reasonable doubt, is without merit. The testimonies of the prosecution witnesses conclusively established Geroncio Mendez's participation in the killing of Roberto Boiser. The fact that the hunting knife was left with another person does not absolve Geroncio Mendez, as his culpability is not altered by whether he used a bolo or a hunting knife, given that he admitted to using a deadly weapon. The prosecution's eyewitness accounts were deemed conclusive in establishing his guilt. On the conviction of Abing Bolioc: The testimony of Celestino Mendez, providing an alibi for Bolioc, cannot prevail over the positive identification made by prosecution witnesses. These witnesses indubitably established that Bolioc was one of the assailants of Roberto Boiser. The claim that Bolioc was a minor at the time of the commission of the crime was denied by the trial court, which correctly ruled that the Child and Youth Welfare Code does not apply to those convicted of offenses punishable by death or reclusion perpetua. However, the Supreme Court found that Bolioc is entitled to a two-degree reduction of the penalty under Article 68 of the Revised Penal Code, considering his alleged minority at the time of the offense. Therefore, he should be sentenced to four years of prision correccional as minimum to eight years and one day of prision mayor medium as maximum for the death of Boiser. On the qualification of the killing of Boiser as murder: The trial court correctly ruled that the killing of Boiser was murder, qualified by evident premeditation and aggravated by treachery. These qualifying and aggravating circumstances, as established by the evidence, justified the imposition of the death penalty. The prosecution's evidence, particularly the eyewitness testimonies, detailed the manner of the attack, demonstrating the presence of these elements. On the killing of Angel Ibañez: The Supreme Court noted that there was apparently no conspiracy to kill Ibañez. Geroncio Mendez chased and stabbed Ibañez twice. The Court concluded that Geroncio Mendez killed Ibañez on the spur of the moment, and therefore, only Geroncio Mendez should be held liable for Ibañez's death. This implies that the killing of Ibañez, while still murder, lacked the premeditation and conspiracy present in Boiser's killing. On the testimony of Celestino Mendez: The testimony of Celestino Mendez, providing an alibi for Bolioc, cannot prevail over the positive identification made by prosecution witnesses. These witnesses indubitably established that Bolioc was one of the assailants of Roberto Boiser.
Main Doctrine
The death penalty imposed for murder, when not unanimously affirmed by the Supreme Court, shall be commuted to reclusion perpetua. A minor accused, even if convicted of offenses punishable by death or reclusion perpetua, is entitled to a two-degree reduction of the penalty if the crime was committed before the age of majority, provided that the Child and Youth Welfare Code applies.