People v. Sanchez
REITERATIONFacts
The Antecedents: On April 13, 1991, at approximately 7:45 p.m., in Barangay Curba, Calauan, Laguna, Nelson Peñalosa and Rickson Peñalosa were shot and killed. An Information for double murder was filed against Antonio L. Sanchez, Luis Corcolon y Fadialan, Landrito "Ding" Peradillas, and Artemio Averion, alleging conspiracy, treachery, evident premeditation, use of a motor vehicle, nighttime, commission for a price, and superior strength. Procedural History: The case underwent several venue changes and raffles before being tried by RTC Branch 160, Pasig City. All accused pleaded not guilty. On December 27, 1996, the RTC convicted all four of the complex crime of double murder, sentencing them to reclusion perpetua and ordering them to pay damages. Accused Antonio L. Sanchez and Artemio Averion appealed. The Petition: Accused-appellants Antonio L. Sanchez and Artemio Averion contended that the trial court erred in not recognizing material inconsistencies between the testimony of state witness Vivencio Malabanan and the physical and scientific evidence, specifically the autopsy and ballistic reports. They also raised issues regarding the credibility of Malabanan and the validity of his affidavit.
Issue(s)
Whether the Supreme Court should consider the alleged material inconsistencies between the state witness's testimony and the physical/scientific evidence. Whether the accused-appellants are guilty beyond reasonable doubt of murder. Whether the crime committed was a complex crime of double murder or two separate counts of murder. Whether the aggravating circumstances of evident premeditation, nighttime, and use of a motor vehicle were properly appreciated. Whether the awarded damages are proper.
Ruling
The Supreme Court modified the decision of the Regional Trial Court. It found accused-appellants Antonio L. Sanchez and Artemio Averion guilty beyond reasonable doubt of two (2) counts of murder, sentencing each to suffer two (2) penalties of reclusion perpetua. The Court also modified the awards for damages.
Ratio Decidendi
On the alleged inconsistencies between the state witness's testimony and physical/scientific evidence: The Court found that the alleged inconsistencies were minor and did not affect the credibility of state witness Vivencio Malabanan. The Court explained that discrepancies could arise due to the dynamic nature of the event, such as the victims shifting positions while being fired upon, and the nature of automatic gunfire. The Court reiterated that minor lapses in a witness's testimony can even bolster credibility by showing the testimony was not coached. The Court also noted that affidavits are generally subordinate to open court declarations, and any inconsistencies in Malabanan's affidavit were minor. The Court emphasized that the testimony of a single credible witness is sufficient for conviction. On the guilt of the accused-appellants: The Court affirmed the trial court's finding that the prosecution adequately established the guilt of the accused beyond reasonable doubt. The Court found Malabanan's testimony detailed and credible, covering the planning, preparation, and execution of the crime, including the order from Mayor Sanchez, the acquisition of a vehicle and radios, the pursuit, and the actual firing. The Court found the defenses of alibi and denial to be without merit in the face of positive testimony. On the classification of the crime: The Court disagreed with the trial court's classification of the crime as a complex crime of double murder. Citing People v. Vargas, Jr., the Court ruled that multiple shots from automatic weapons, even if caused by a single act of pressing the trigger, constitute several acts producing several offenses. Since Malabanan testified to three bursts of gunfire, the accused were liable for two counts of murder, not a complex crime. On the aggravating circumstances: The Court appreciated the aggravating circumstances of treachery, evident premeditation, and use of a motor vehicle. Treachery was present as the attack was sudden and afforded no opportunity for defense. Evident premeditation was established by the clear planning and sufficient time lapse between determination and execution. The use of a motor vehicle was evident. However, the Court did not appreciate the aggravating circumstance of nighttime, as the prosecution failed to show that the accused specifically sought the darkness to facilitate the crime. On the awarded damages: The Court modified the awards for damages. It disallowed the P50,000.00 for actual damages due to lack of receipts. It also disallowed damages for loss of earning capacity due to the lack of unbiased proof, as only a self-serving statement was presented. The Court sustained the P30,000.00 exemplary damages per victim due to the presence of aggravating circumstances. It affirmed the P50,000.00 moral damages for Rickson Peñalosa's heirs and also sustained the award for Nelson Peñalosa's heirs, noting that while the common-law wife testified to mental anguish, she was not entitled to share in the moral damages award.
Main Doctrine
The Supreme Court modified the RTC decision, finding the accused guilty of two counts of murder instead of a complex crime of double murder, and adjusted the penalties and damages.