People v. Parro
REITERATIONFacts
The Antecedents: The defendant and appellant, Rufino Parro, harbored personal enmity towards his brother, Silverio Parro, due to disputes over family property. Motivated by this enmity, Rufino Parro procured Gabino Calindatas, an ignorant individual, to kill Silverio Parro and a grandniece, Paciencia Sendencia, for a reward of P60 and a promise that Calindatas would not be prosecuted after three years. Following Rufino Parro's instructions, Calindatas waylaid Silverio Parro and Paciencia Sendencia on the night of April 16, 1913, in an uninhabited place on the seashore, and killed them with a dagger. Calindatas then reported the execution of the orders to Rufino Parro, who subsequently arranged for the bodies to be buried at sea. Procedural History: The trial court sentenced Rufino Parro to cadena perpetua, to indemnify the heirs of Silverio Parro and Paciencia Sendencia in the amount of P500 each, and to pay the costs. The Petition: The defendant and appellant appealed the decision of the trial court.
Issue(s)
Whether the defendant and appellant is guilty as principal by inducement for the crime of murder. Whether the aggravating circumstances of evident premeditation, relationship, commission in the night time, and in an uninhabited place were present. Whether the penalty imposed by the trial court is in accordance with law.
Ruling
The Supreme Court affirmed the conviction of the defendant and appellant for murder by inducement. The Court modified the penalty imposed by the trial court, sentencing Rufino Parro to be hanged until dead in accordance with law, with costs. The Court also affirmed the indemnification of the heirs of the deceased.
Ratio Decidendi
On the issue of guilt as principal by inducement: The Court held that the facts constitute murder by inducement for a price, making the defendant guilty as principal in the commission of the crime. Article 13, No. 2 of the Penal Code defines principals as those who induce or compel others to commit a crime. In this case, Rufino Parro directly procured Gabino Calindatas to commit the murders for a reward, thereby inducing the commission of the crime. The Court cited jurisprudence to support this classification of guilt. On the presence of aggravating circumstances: The Court found that the aggravating circumstances of evident premeditation, relationship, and commission in the night time and in an uninhabited place concurred in the commission of the crime. Evident premeditation was established by the defendant's procurement of an assassin and the planning involved. The circumstance of relationship was present as the victim Silverio Parro was the defendant's brother. The commission of the crime in the night time and in an uninhabited place further aggravated the offense. The Court noted that these circumstances were offset by no mitigating circumstances. On the penalty imposed: The Court, agreeing with the recommendation of the Attorney-General and following the mandatory precepts of the law, found that the penalty of cadena perpetua imposed by the trial court was not in accordance with the law given the presence of aggravating circumstances and the nature of the crime. The Court mandated that the penalty for murder, with the attendant aggravating circumstances and no mitigating circumstances, should be death. Therefore, the Court eliminated the provision for life imprisonment and in lieu thereof sentenced the defendant and appellant Rufino Parro to be hanged until dead in accordance with law.
Main Doctrine
A person who procures another to commit murder for a price, is guilty as principal by inducement, and shall suffer the penalty of death, with aggravating circumstances of evident premeditation, relationship, commission in the night time, and in an uninhabited place, offset by no mitigating circumstances.