People v. Centeno
REITERATIONFacts
The Antecedents: The accused-appellants, Francisco Centeno alias "Panchito", Juan Centeno alias "Totok", and Manuel Centeno alias "Iyao", were charged with murder for allegedly conspiring and, armed with firearms, treachery and evident premeditation, inflicting wounds on Nestor Asistido which caused his death. Procedural History: The trial court found the accused-appellants guilty of homicide with the aggravating circumstance of superior strength, offset by the mitigating circumstance of voluntary surrender. They were sentenced to imprisonment and ordered to indemnify the heirs of the deceased. The decision was appealed to the Court of Appeals. The Petition: The Court of Appeals found the accused-appellants guilty of murder, citing treachery and evident premeditation. However, due to the penalty involved, it certified the case to the Supreme Court. The Supreme Court initially remanded the case back to the Court of Appeals for proper action. Subsequently, the Supreme Court reviewed the amended decision of the Intermediate Appellate Court and adopted it in its entirety.
Issue(s)
Whether the accused-appellants are guilty of murder. Whether the penalty imposed by the trial court should be modified. Whether the civil liability awarded to the heirs of the deceased should be increased.
Ruling
The Supreme Court found the accused-appellants Francisco Centeno alias "Panchito", Juan Centeno alias "Totok", and Manuel Centeno alias "Iyao" guilty beyond reasonable doubt of the crime of Murder. The sentence of imprisonment imposed by the trial court on each of the accused-appellants was modified to reclusion perpetua, and the indemnification for the death of Nestor Asistido was increased to Thirty Thousand Pesos (P30,000.00). In all other respects, the judgment of the trial court was affirmed.
Ratio Decidendi
On whether the accused-appellants are guilty of murder: The Court affirmed the findings of the Intermediate Appellate Court that the circumstances of treachery and evident premeditation were clearly attendant to the commission of the crime. These circumstances qualified the killing to murder under Article 248 of the Revised Penal Code. The Court found the evidence presented sufficient to establish the guilt of the accused beyond reasonable doubt for the crime of murder as charged in the information. The appellate court's assessment of the evidence was found to be sufficiently thorough and exhaustive, leading to the conclusion that the killing was committed with treachery and evident premeditation. On whether the penalty imposed by the trial court should be modified: The trial court found the accused guilty of homicide with aggravating and mitigating circumstances. However, the Court of Appeals, upon review, found the elements of murder to be present, specifically treachery and evident premeditation. The penalty for murder under Article 248 of the Revised Penal Code is reclusion temporal in its maximum period to death. The Supreme Court, adopting the amended decision of the Intermediate Appellate Court, modified the sentence of imprisonment imposed by the trial court to reclusion perpetua, which is the appropriate penalty for murder when no modifying circumstances are present or when the aggravating circumstances outweigh the mitigating ones, considering the nature of the crime and the attendant circumstances. On whether the civil liability awarded to the heirs of the deceased should be increased: The trial court awarded P12,000.00 for the death of Nestor Asistido, P33,696.00 for loss of income, and P10,000.00 for moral damages. Following the precedent set in People v. de la Fuente (126 SCRA 518), wherein the civil liability was increased to P30,000.00, the Supreme Court increased the award for indemnification for the death of Nestor Asistido from P12,000.00 to P30,000.00. The award for actual moral damages, being supported by evidence, was affirmed. The increase in indemnification reflects the Court's policy to provide just compensation to the heirs of victims of violent crimes.
Main Doctrine
The Supreme Court affirmed the conviction for murder, modified the penalty to reclusion perpetua, and increased the civil indemnity awarded to the heirs of the victim.