People v. Benedicto Dapitan y Martin
REITERATIONFacts
The Antecedents: The facts involve the elements of Robbery with Homicide under Philippine Law. Procedural History: An information was filed on 1986-08-07 charging the accused with Robbery with Homicide. The accused pleaded not guilty on 1986-11-25. Trials and hearings were conducted in 1987 and thereafter, with reception of evidence beginning 1987-08-24. On 1989-05-05 the Regional Trial Court rendered judgment finding the accused guilty beyond reasonable doubt and sentenced him to reclusion perpetua and ordered civil indemnity in the amount of P30,000.00. The accused filed a notice of appeal on 1989-05-11. The records were erroneously transmitted to the Court of Appeals and later transmitted to the Supreme Court. The Supreme Court rendered the present decision on 1991-05-23. The Petition: The accused-appellant's sole assignment of error is that the trial court erred in not applying the Indeterminate Sentence Law in his favor, urging appreciation of mitigating circumstances and requesting an indeterminate penalty with a lower minimum term.
Issue(s)
Whether the trial court erred in not applying the Indeterminate Sentence Law in favor of the accused. Whether the imposition of reclusion perpetua violated the accused's right to due process or constitutes cruel, degrading or inhuman punishment. Whether mitigating circumstances should be appreciated to reduce the penalty for the crime charged. Whether the civil indemnity awarded by the trial court should be modified.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court finding accused Benedicto Dapitan y Martin guilty beyond reasonable doubt of Robbery with Homicide and imposed the penalty of reclusion perpetua. The Court modified the award of civil indemnity, increasing it from P30,000.00 to P50,000.00. Costs were imposed against the accused-appellant.
Ratio Decidendi
On Whether the Indeterminate Sentence Law applies: The Court held that the Indeterminate Sentence Law (Act No. 4103) does not apply to persons convicted of offenses punishable by death or life imprisonment, citing Section 2 of the law as excluding such offenders. The crime of Robbery with Homicide under Article 294, par. 1 of the Revised Penal Code is punishable with death or reclusion perpetua; with the abolition of the death penalty the single indivisible penalty now applicable is reclusion perpetua which is tantamount to life imprisonment for purposes of exclusion under the Indeterminate Sentence Law. Applying this statutory exclusion, the Court concluded that the trial court correctly declined to apply an indeterminate sentence. The Court emphasized statutory interpretation and the explicit language of Section 2 of Act No. 4103 in reaching this conclusion. Thus, the accused cannot avail himself of an indeterminate sentence even where mitigating circumstances are argued. On Whether reclusion perpetua violated due process or constituted cruel, degrading or inhuman punishment: The Court found no deprivation of due process, reiterating settled requisites: the presence of a competent tribunal, lawful acquisition of jurisdiction, opportunity to be heard, and judgment after lawful hearing. The Court applied established precedents, including People v. Castillo and Banco Espanol de Filipino v. Palanca, to demonstrate that the accused received full opportunity to contest the charge and to present evidence. Regarding the Eighth Amendment-equivalent claim, the Court held that reclusion perpetua is a punishment recognized by successive constitutions and is not per se cruel, degrading or inhuman; it cited Section 19(1) of the 1987 Constitution which prohibits cruel punishments but expressly contemplates reclusion perpetua as the reduced form of prior death sentences. The Court relied on People v. Estoista and related authority to state that only punishments that are flagrantly oppressive or involve torture would meet the constitutional proscription. Consequently, imposition of reclusion perpetua, being lawful and prescribed by statute for the crime, did not offend due process or the constitutional prohibition against cruel punishment. On Appreciation of Mitigating Circumstances and Article 63, Revised Penal Code: The Court reasoned that because the special complex crime is now punished by a single indivisible penalty (reclusion perpetua), the first paragraph of Article 63 of the Revised Penal Code requires application of that single penalty "regardless of any mitigating or aggravating circumstances that may have attended the commission of the deed." The Court therefore held that mitigating circumstances, even if present, cannot alter the penalty imposed for an offense carrying a single indivisible penalty. The Court applied this provision directly to affirm the trial court's imposition of reclusion perpetua. The Court observed that factual assertions by the accused regarding lesser perversity or voluntary surrender did not alter the legal consequence arising from Article 63. On the Civil Indemnity: Applying precedent, including People v. Sison and People v. Sazon, the Court increased the civil indemnity from P30,000.00 to P50,000.00. The Court exercised its supervisory power to adjust the civil award in line with recent jurisprudence and consistent remedial principles for victims' heirs.
Main Doctrine
Where a special complex crime prescribes a single indivisible penalty by law, that penalty must be applied regardless of mitigating or aggravating circumstances; the Indeterminate Sentence Law is inapplicable to offenses punishable by death or life imprisonment.