People v. Manalili
REITERATIONFacts
The Antecedents: On February 1, 1990, a Ballesteros Liner bus was held up in Cordon, Isabela. During the incident, three passengers, Alfredo Tango (driver), Sonny Quintua (bus helper), and Nestor Agustin (passenger), were killed, and one passenger, William Simmapan, was injured. The perpetrators, identified as Willy Manalili and Danilo Reyes along with three others, attempted to rob the passengers but were repelled by a resisting passenger, leading to an exchange of gunfire. One of the robbers was killed, and Manalili was wounded. Procedural History: Three separate Informations were filed: (a) attempted robbery, (b) killing three persons (Alfredo Tango, Sonny Quintua, Nestor Agustin) with alleged evident premeditation and treachery, and (c) shooting and wounding three other persons (frustrated murder) and illegal possession of firearms. The Regional Trial Court (RTC) found the accused guilty of attempted robbery with homicide, sentencing them to reclusion perpetua, and acquitted them of illegal possession of firearms. The case was elevated to the Supreme Court on appeal. The Petition: Appellants alleged that the RTC erred in giving undue credence to prosecution witnesses and disregarding their alibi, and in finding them guilty of attempted robbery with homicide.
Issue(s)
Whether the trial court erred in giving undue credence to the testimonies of the prosecution witnesses and disregarding the defense of alibi. Whether the trial court erred in finding the accused guilty beyond reasonable doubt of the crime of attempted robbery with homicide. Whether the accused could be convicted of attempted robbery with homicide despite the separate informations filed for attempted robbery, multiple murder, and frustrated murder; and whether the accused could be convicted of multiple frustrated murder. Whether the accused could be convicted of murder for the deaths of Alfredo Tango and Sonny Quintua, despite being acquitted of the death of Nestor Agustin and illegal possession of firearms; and on the penalty.
Ruling
The Supreme Court modified the decision of the trial court. Appellants were found guilty of attempted robbery and double murder (of Alfredo Tango and Sonny Quintua), and acquitted of frustrated murder and the death of Nestor Agustin. They were sentenced to four months of arresto mayor for attempted robbery and two terms of reclusion perpetua for the double murder. They were ordered to pay P50,000.00 as civil indemnity to the heirs of each victim.
Ratio Decidendi
On the issue of credibility of witnesses and alibi: The Court affirmed the trial court's assessment of the prosecution witnesses' credibility, finding their positive identification of the appellants sufficient to overcome the defense of alibi. The Court noted that the witnesses had ample opportunity to see and identify the malefactors, and their testimonies were straightforward and categorical. The Court found the alibi weak and unconvincing, especially since the testimonies of the accused and their witnesses were identical, suggesting rehearsal. The Court reiterated the rule that positive identification of the accused by credible witnesses destroys the defense of alibi. On the conviction for attempted robbery with homicide: The Court disagreed with the trial court's conviction for the special complex crime of attempted robbery with homicide. It held that the appellants were not properly charged with this offense in any of the three Informations filed. Convicting them of a crime not charged would violate their constitutional right to be informed of the nature and cause of the accusation. Therefore, the Court limited the conviction for the first case to attempted robbery, as the elements of consummated robbery were not fully proven, and the death of one of the robbers was not caused by the appellants. On the conviction for multiple frustrated murder and attempted robbery with homicide: The Court acquitted the appellants of multiple frustrated murder due to insufficient evidence. The alleged injured victim, William Sinampan, did not testify, and no medical certificate was presented to establish the extent and gravity of his injuries. The trial court also did not make a specific ruling on this charge, thus the presumption of innocence prevailed. On the conviction for multiple murder and the penalty: The Court found that the appellants were guilty of the double murder of Alfredo Tango and Sonny Quintua, as charged in the second Information. The Court noted that while the Information was duplicitous, charging both illegal possession of firearms and murder, the appellants waived their right to object by not moving for quashal before arraignment. The Court found that the killings of Tango and Quintua were characterized by treachery, as they were shot suddenly and without opportunity to defend themselves. However, the Court acquitted them of the death of Nestor Agustin, as it was not clearly established who shot him, and he was likely hit during the exchange of gunfire with a resisting passenger. For attempted robbery, the penalty imposed was four months of arresto mayor. For the double murder, each appellant was sentenced to two terms of reclusion perpetua, with civil indemnity to the heirs of the victims. The Court clarified that while the penalty for murder could have been death, the constitutional prohibition against the imposition of the death penalty at the time, and the non-retroactivity of RA 7659, reduced the penalty to reclusion perpetua.
Main Doctrine
An accused cannot be convicted of an offense not charged in the information, even if proven, as it violates the constitutional right to be informed of the nature and cause of the accusation. However, failure to object to a duplicitous information before arraignment constitutes a waiver, allowing conviction for all offenses proven.