People v. Lachica
REITERATIONFacts
The Antecedents: Romeo Lachica and Jilly Sigador were charged with murder for the stabbing death of fellow prisoner Dominador Aguilar inside New Bilibid Prison. Aguilar sustained eight stab wounds, one of which was fatal. Lachica and Sigador were apprehended by prison guards shortly after the incident and surrendered the knives used. Both gave extrajudicial statements confessing to the killing. Procedural History: The accused were found guilty of murder by the Criminal Circuit Court of Rizal and sentenced to death. Sigador's sentence was later carried out by electrocution. The case proceeded as a mandatory review for Lachica. The Petition: Accused-appellant Romeo Lachica appealed his conviction.
Issue(s)
Whether the accused-appellant Romeo Lachica is guilty of murder. Whether the killing was committed with treachery and evident premeditation. Whether quasi-recidivism is a special aggravating circumstance. Whether the penalty of death is appropriate.
Ruling
The Supreme Court affirmed the conviction of Romeo Lachica for murder, but commuted the death sentence to reclusion perpetua due to lack of necessary votes. The Court ordered Lachica to indemnify the heirs of the deceased in the amount of P30,000.00.
Ratio Decidendi
On the guilt of Romeo Lachica: The Court found that the evidence on record adequately supported the conviction. Lachica's extrajudicial confession, wherein he admitted to stabbing Dominador Aguilar, constituted the strongest evidence of his guilt. This confession was obtained before the effectivity of the 1973 Constitution, thus the right to silence and counsel was not a ground to invalidate it. Furthermore, a co-prisoner, Rodolfo Andaya, testified that Lachica and Sigador planned and executed the killing. The trial court also found that Lachica and Sigador pleaded guilty to the crime charged, and when informed of the consequences, they manifested their awareness of being punished in accordance with law. On treachery and evident premeditation: The facts on record adequately supported the lower court's conclusion that the crime was committed with treachery and evident premeditation. The victim, Dominador Aguilar, was stabbed inside his cell while seated and writing, indicating that he was not in a position to defend himself. The plan to kill Aguilar was made the night before, demonstrating evident premeditation. The accused stealthily slipped into the dormitory and cell, and attacked without warning. On quasi-recidivism as a special aggravating circumstance: The Court held that the fact that accused Lachica is a quasi-recidivist — having committed the new offense of murder while serving sentence for a previous crime — more than justifies the death sentence meted out by the lower court. Quasi-recidivism is a special aggravating circumstance which imposes the maximum of the penalty for the new offense without regard to the presence or absence of other aggravating or mitigating circumstances, as provided for in Article 160 of the Revised Penal Code. On the penalty of death: While the Court found that quasi-recidivism justified the imposition of the death penalty, for lack of the necessary votes, the penalty was commuted to reclusion perpetua. Some Justices held the view that the death sentence should not be imposed as the accused had been incarcerated for more than ten years. The Court also ordered Lachica to indemnify the heirs of the deceased Dominador Aguilar in the amount of P30,000.00.
Main Doctrine
Quasi-recidivism is a special aggravating circumstance that imposes the maximum penalty for the new offense, regardless of other aggravating or mitigating circumstances. However, for lack of necessary votes, the death sentence was commuted to reclusion perpetua.