People v. De la Cruz
REITERATIONFacts
The Antecedents: On the morning of 13 October 1981, the bodies of Rizal Saldino (barangay captain) and Jaime Ceria were brought to the INP Station. Rizal Saldino had thirteen gunshot wounds, four stab wounds, and two contusions. Jaime Ceria had four gunshot wounds, five stab wounds, five lacerated wounds, five abrasion wounds, and three contusions. Alberto de la Cruz and co-accused were charged with "Kidnapping with Double Murder." The complaint was amended to include PC officers and soldiers. The case was initially forwarded to the Court of First Instance, then to the JAGO, but the motion for transfer was reconsidered, and the case remained with the civil court. An Amended Information was filed, and later a Second Amended Information included more accused military personnel. Procedural History: The trial court granted the motion for a separate trial for the accused civilians. SN2 Ramon Amorsolo was killed during the pendency of the case, and 2nd Lt. Armando Dolor was dropped from the information due to insufficient evidence. The prosecution's version, based on eyewitness testimonies, stated that soldiers and armed civilians went to the victims' houses, searched for firearms, and took Rizal and Jaime to Eligio Lacuban's house where they were maltreated. Later, they were brought to a boundary area where they were stabbed and shot. The accused civilians presented the defense of denial and alibi. The RTC rendered a decision finding Alberto de la Cruz guilty of two counts of Murder, sentencing him to two life imprisonments, and acquitting the other accused civilians. The RTC dismissed the case against those who died during the pendency. The Petition: Appellant Alberto de la Cruz appealed the RTC decision, arguing that the court contradicted itself by finding the PC soldiers killed the victims in cold blood while convicting him, and by discrediting part of an eyewitness's testimony while believing another part. The appellee argued that the RTC's finding of PC soldiers killing the victims was a partial determination and that the maxim falsus in uno, falsus in omnibus is not strictly applied.
Issue(s)
Whether the trial court erred in convicting appellant Alberto de la Cruz of murder on two counts. Whether the trial court committed judicial inconsistency in its evaluation of evidence and appreciation of facts. Whether the killing was qualified by evident premeditation, treachery, or abuse of superior strength. Whether the penalty of life imprisonment was correctly imposed. Whether civil indemnity should be awarded to the heirs of the victims. Whether the trial court erred in not finding appellant Alberto de la Cruz innocent of the crime charged.
Ruling
The Supreme Court affirmed the conviction of Alberto de la Cruz for two counts of murder but modified the penalty to reclusion perpetua and ordered the payment of civil indemnity to the heirs of the victims. The Court also expressed displeasure at the lack of action against the accused soldiers and ordered the trial court to exert efforts to bring them under its jurisdiction.
Ratio Decidendi
On the conviction of appellant Alberto de la Cruz for murder on two counts: The Supreme Court agreed with the appellee that the trial court's statement that the victims "were killed by the PC soldiers in cold blood" did not exclude the participation of the accused civilians, particularly the appellant. The trial court detailed the appellant's participation based on the eyewitness testimony of Segismundo Saldino, finding it credible despite rigorous cross-examination. The Court found the appellant's alibi and explanation for his presence unconvincing, especially when contrasted with the victims' maltreatment despite similar suspicions of being NPA members. The Court concluded that the appellant's guilt was established beyond reasonable doubt. On the alleged judicial inconsistency regarding evaluation of evidence and appreciation of facts: The Supreme Court reiterated that the maxim falsus in uno, falsus in omnibus is not a mandatory rule and that a witness's testimony may be believed in part and disbelieved in part. The Court found it reasonable to believe Segismundo Saldino's testimony regarding the appellant's participation while discrediting his testimony about Charlie Tulali skinning Jaime Ceria's foot. The Court also disregarded Manuel Lacuban's testimony that Segismundo Saldino could not have witnessed the killing because Segismundo slept in his house, deeming Manuel's testimony as coming from a "polluted source" and belied by other declarations. On whether the killing was qualified by evident premeditation, treachery, or abuse of superior strength: The Court found that evident premeditation was not sufficiently proved because it was unclear when the plan to kill was hatched, and the initial objective appeared to be to force the victims to reveal the location of firearms. Treachery was also not sufficiently proved, as the victims might have perceived an assault was forthcoming when the assailants entered their houses. However, the Court found that abuse of superior strength was clearly borne out by the evidence, considering the greater number of assailants and their weapons, making the two victims clearly outmatched. This abuse of superior strength qualified the killing to murder. On the imposition of the penalty of life imprisonment: The Supreme Court clarified that "life imprisonment" is not the same as "reclusion perpetua" and admonished trial judges to use the proper legal terminology due to their different legal accessories and effects. The Court modified the trial court's sentence of "life imprisonment" to "reclusion perpetua" for each count of murder, as abuse of superior strength is a qualifying circumstance for murder under Article 248 of the Revised Penal Code, and in the absence of other aggravating or mitigating circumstances, the penalty should be imposed in its medium period. On the award of civil indemnity: The Supreme Court noted that the trial court did not award civil indemnity. Since the records did not indicate that a separate civil action was instituted, or that the right to file one was waived or reserved, the civil action was deemed impliedly instituted with the criminal action. Therefore, the appellant was ordered to pay a civil indemnity of P50,000.00 to the heirs of Rizal Saldino and another P50,000.00 to the heirs of Jaime Ceria, in conformity with current jurisprudence. On whether the trial court erred in not finding appellant Alberto de la Cruz innocent of the crime charged: The Supreme Court found the appellant's guilt was established beyond reasonable doubt based on the eyewitness testimony and the lack of credibility in his alibi. This implicitly addresses the issue of innocence, as the conviction implies a finding of guilt beyond a reasonable doubt.
Main Doctrine
Abuse of superior strength qualifies the killing to murder, and the penalty should be reclusion perpetua. Life imprisonment is not synonymous with reclusion perpetua. Civil indemnity must be awarded to the heirs of the victims.