People v. Machete
REITERATIONFacts
The Antecedents: On January 20, 1987, Police Officers Panfilo Mendoza and Leonilo Maranga were assigned as security officers at a public benefit dance. While seated at a traveling store, Ronilo Machete, along with Rene O. Machete, approached them. Ronilo Machete grabbed Pat. Mendoza's armalite rifle and pointed it at Pat. Maranga, while Rene O. Machete took Pat. Maranga's rifle. As Pat. Mendoza followed to retrieve his rifle, Ronilo Machete shot him multiple times. Ronilo Machete then fired at the crowd, hitting Juanito Narrido. Pat. Mendoza sustained six gunshot wounds, two of which indicated he was already on the ground. Ronilo Machete and Rene O. Machete fled with the rifles. Procedural History: Ronilo Machete and Rene O. Machete were charged in three separate informations for murder with assault upon a person in authority (Criminal Case No. N-1468), attempted murder of Juanito Narrido (Criminal Case No. N-1469), and attempted murder of Elmeo Sabah (Criminal Case No. N-1470). Only Ronilo Machete was prosecuted as Rene O. Machete eluded arrest. Ronilo Machete pleaded not guilty. After joint trial, the Regional Trial Court (RTC) convicted Ronilo Machete of murder and serious physical injuries, sentencing him to reclusion perpetua for murder and an indeterminate sentence for serious physical injuries. He was acquitted of attempted murder in Criminal Case No. N-1470. The Petition: Ronilo Machete appealed, assigning as errors the RTC's finding of guilt beyond reasonable doubt, its credence to prosecution witnesses, and its finding of murder despite the absence of treachery.
Issue(s)
Whether the trial court erred in finding the accused-appellant guilty beyond reasonable doubt. Whether the trial court erred in finding the accused-appellant guilty of murder despite the absence of the qualifying circumstance of treachery.
Ruling
The Supreme Court modified the decision of the trial court in Criminal Case No. N-1468, finding the accused-appellant guilty of homicide instead of murder. The decisions in Criminal Cases Nos. N-1469 and N-1470 were affirmed in toto.
Ratio Decidendi
On the issue of guilt beyond reasonable doubt: The Court gave great respect to the trial court's evaluation of the credibility of witnesses, a primary task of trial courts. The prosecution witnesses, Pat. Maranga and Juanito Narrido, positively testified that appellant Ronilo Machete shot Pat. Mendoza and fired at the crowd. Their testimony was affirmative and forthright, and the appellant failed to present evidence of any sinister motive for them to testify falsely. The Court noted that the appellant's version of events, where his cousin Rene Machete was solely responsible, was uncorroborated by independent evidence and contradicted by the prosecution's eyewitness accounts. Furthermore, the appellant's conduct after the incident, including going into hiding for over four years, was construed by the trial court as indicative of guilt, consistent with the rule that flight from the scene of the crime is indicative of guilt. On the issue of treachery: The Court agreed with the Solicitor General and the appellant that treachery was not sufficiently proven. While the shooting was sudden, there was no evidence that the mode of assault was consciously and deliberately adopted to insure the execution of the crime without risk to the offender. The shooting appeared to be an instantaneous reaction to Pat. Mendoza's attempt to follow the Machetes who had taken their firearms. Pat. Mendoza, by following them, may have had an inkling that he would be assaulted or shot, negating the element of surprise or lack of opportunity to defend himself. The circumstances did not show that the appellant consciously and deliberately adopted the manner of attack to avoid risk to himself; rather, it seemed to be a reaction to prevent Pat. Mendoza from following them as they escaped. The prosecution failed to prove treachery as indubitably as the crime itself, thus it could not qualify the killing to murder.
Main Doctrine
The prosecution failed to prove treachery beyond reasonable doubt, thus the killing of a police officer, absent other qualifying circumstances, is homicide and not murder. Flight of the accused is indicative of guilt.