People v. Abapo
REITERATIONFacts
The Antecedents: The case involves two separate informations for murder filed against Celestino Abapo. The first, Criminal Case No. 64831, was for the death of Edgardo Bondoc on September 13, 1985. The second, Criminal Case No. 78198, was for the death of Alfredo Raranga on August 8, 1985. The accused was apprehended on May 25, 1989, after being at large. He pleaded not guilty to both charges. Trial was conducted jointly. Procedural History: The Regional Trial Court of Pasig, Metro Manila, Branch 164, rendered a Joint Decision on February 26, 1990, convicting Celestino Abapo of two counts of murder and imposing the penalty of life imprisonment for each death, with indemnity to the heirs. The accused appealed this decision. The Petition: The accused appealed his conviction, raising several contentions regarding the sufficiency of evidence, the credibility of witnesses, the presence of qualifying circumstances, and the proper penalty.
Issue(s)
Whether the guilt of the accused-appellant was proven beyond reasonable doubt for the murder of Edgardo Bondoc. Whether the guilt of the accused-appellant was proven beyond reasonable doubt for the murder of Alfredo Raranga. Whether treachery qualified the killings to murder in both cases. Whether the penalty imposed by the trial court was correct, differentiating between 'life imprisonment' and 'reclusion perpetua'. Whether the indemnity awarded to the heirs was proper.
Ruling
The Supreme Court affirmed the conviction of the accused-appellant for two counts of murder. It modified the imposed penalty, clarifying that 'reclusion perpetua' is the correct penalty under the Revised Penal Code, not 'life imprisonment,' and increased the indemnity to P50,000.00 for each set of heirs.
Ratio Decidendi
On the murder of Edgardo Bondoc (Criminal Case No. 64831): The Court found the testimony of the sole eyewitness, Pepito Reyes, to be credible and sufficient to establish the guilt of the accused beyond reasonable doubt. Pepito Reyes positively identified Celestino Abapo as the assailant. The Court rejected the appellant's alibi, noting that his defense was not strong enough to overcome the positive identification. On the murder of Alfredo Raranga (Criminal Case No. 78198): The Court upheld the trial court's rejection of the defense witness Luisa Caraquel's testimony, finding her delay in coming forward and her claimed fear inconsistent. The Court gave full faith and credit to the testimony of the prosecution witness, Evelvie Gavina, who positively identified the appellant. On the qualification of treachery: In both cases, the Court found that treachery was sufficiently proven. For Edgardo Bondoc, the victim was shot while attempting to flee, with his back turned to the assailant. For Alfredo Raranga, the victim was shot unexpectedly while seated and undergoing a manicure. In both instances, the assailants took advantage of the victim's defenseless position and the suddenness of the attack, ensuring the accomplishment of the crime without risk to themselves. On the penalty of 'reclusion perpetua' versus 'life imprisonment': The Court clarified a common misconception, reiterating its established jurisprudence that 'reclusion perpetua' and 'life imprisonment' are distinct penalties. 'Reclusion perpetua' is a penalty under the Revised Penal Code, carrying specific accessory penalties and a minimum duration of 30 years, while 'life imprisonment' is typically imposed under special laws and does not have a fixed duration or the same accessory penalties. The trial court erred in imposing 'life imprisonment' as the English equivalent of 'reclusion perpetua.' Therefore, the Court imposed two sentences of 'reclusion perpetua' on the appellant. On the indemnity: The Court increased the indemnity awarded to the heirs of each victim from P30,000.00 to P50,000.00, in accordance with prevailing jurisprudence at the time of the decision.
Main Doctrine
The Court affirmed the conviction of the accused for two counts of murder, clarifying the distinction between 'reclusion perpetua' and 'life imprisonment' and increasing the indemnity to P50,000.00 for each victim's heirs.