People v. Amigo
ABANDONMENTFacts
The Antecedents: Patricio Amigo was initially charged with frustrated murder for stabbing Benito Ng Suy with a knife, inflicting multiple stab wounds. An amended Information was filed charging murder after the victim died. The prosecution presented evidence that on December 29, 1989, after a minor vehicular collision between the victim's Ford Fiera and a Toyota Tamaraw driven by Virgilio Abogada (with Amigo as passenger), Amigo confronted the victim. After a verbal exchange where the victim identified himself as Chinese, Amigo left, returned, and without provocation, stabbed the victim multiple times. The victim was brought to the hospital and later airlifted to Manila, where he died due to sepsis. Procedural History: The Regional Trial Court (RTC) found Patricio Amigo guilty beyond reasonable doubt of murder, sentencing him to reclusion perpetua and ordering him to pay damages. The accused appealed, arguing that the penalty imposed was erroneous given the effectivity of the 1987 Constitution, which abolished the death penalty. The Petition: The accused-appellant contends that the RTC erred in imposing reclusion perpetua, arguing that the penalty should have been reclusion temporal in its medium period, as the death penalty was abolished by the 1987 Constitution.
Issue(s)
Whether the penalty of reclusion perpetua was correctly imposed for the crime of murder in light of the 1987 Constitution, considering the abolition of the death penalty. Whether, in the absence of aggravating or mitigating circumstances, the medium period of the penalty prescribed by Article 248 of the Revised Penal Code, which is reclusion perpetua, was correctly applied.
Ruling
The Supreme Court affirmed the decision of the RTC, holding that the penalty of reclusion perpetua was correctly imposed. The Court reiterated its ruling that Article III, Section 19(1) of the 1987 Constitution prohibits the imposition of the death penalty but does not alter the range of penalties for murder, which remains reclusion temporal in its maximum period to death, with the death penalty reduced to reclusion perpetua. The minimum and medium periods of the penalty remain unchanged.
Ratio Decidendi
On the imposition of reclusion perpetua and the effect of the 1987 Constitution on the penalty for murder: The accused-appellant argued that the penalty for murder should be reclusion temporal in its medium period because the death penalty was abolished by the 1987 Constitution. However, the Supreme Court, in reconsidering its previous rulings, reverted to the original interpretation of Article III, Section 19(1) of the Constitution. This provision merely prohibits the imposition of the death penalty and reduces it to reclusion perpetua when already imposed, but it does not change the range of the penalties prescribed by Article 248 of the Revised Penal Code. The Court emphasized that the Constitution's language is plain and does not expressly or by clear implication require a modification of the minimum and medium periods of the penalty for murder. Therefore, the range of reclusion temporal in its maximum period to death, with death reduced to reclusion perpetua, remains the applicable penalty structure. The Court explicitly stated, "Instead, we return to our original interpretation and hold that Article III, Section 19(1) does not change the periods of the penalty prescribed by Article 248 of the Revised Penal Code except only insofar as it prohibits the imposition of the death penalty and reduces it to reclusion perpetua. The range of the medium and minimum penalties remains unchanged." On the application of the medium period of the penalty in the absence of modifying circumstances: The Court found no generic aggravating or mitigating circumstances attending the commission of the offense. Consequently, the applicable sentence is the medium period of the penalty prescribed by Article 248 of the Revised Penal Code. Under the doctrine reaffirmed in this case, this medium period is reclusion perpetua. The Court acknowledged that this interpretation might lead to perceived inequities but stressed that such is the will of the Constitution, not the Court's making, and that any modification of penalties is a legislative prerogative. The Court concluded that the penalty imposed by the RTC was in accordance with the law and jurisprudence.
Main Doctrine
The penalty for murder under Article 248 of the Revised Penal Code, as modified by Article III, Section 19(1) of the 1987 Constitution, remains the same range of reclusion temporal in its maximum period to death, with the death penalty reduced to reclusion perpetua. The prohibition against the death penalty does not alter the minimum and medium periods of the penalty for murder.