People v. Inggo
NEW DOCTRINEFacts
The Antecedents: On August 15, 1996, Leonisa Insic was requested by Rosemarie Reinante to do household chores. While Leonisa was eating lunch, she saw the appellant Pablito Inggo buy a bottle of beer. Due to insufficient cash for change, Leonisa Insic was asked to get change. Upon returning, Leonisa Insic and appellant exchanged words regarding the change. Rosemarie Reinante arrived and intervened, attempting to give the change to appellant. An argument ensued between appellant and Rosemarie Reinante. Suddenly, appellant loosened his belt, removed it, chased Rosemarie Reinante, and stabbed her. Leonisa Insic attempted to intervene, giving Rosemarie Reinante an opportunity to run towards the road. Appellant again chased Rosemarie Reinante, caught up with her, and stabbed her. Rosemarie Reinante fell on the road and was later pronounced dead on arrival at the hospital. Procedural History: The Regional Trial Court of Dipolog City, Branch 8, convicted appellant Pablito T. Inggo of murder, sentencing him to death and ordering him to pay damages. The Petition: Appellant appealed the decision, assigning errors regarding the appreciation of qualifying and aggravating circumstances, the imposition of the death penalty, and alleging he was framed-up.
Issue(s)
Whether appellant's guilt for murder was proved beyond reasonable doubt, and if not murder, what crime was committed. Whether the qualifying circumstance of treachery attended the commission of the crime. Whether the aggravating circumstance of disregard of sex and the alternative circumstance of intoxication were present, and whether these circumstances were properly alleged. Whether the penalty of death was properly imposed, and what the correct penalty should be. Whether the award of damages is proper, and what the correct amount of damages should be.
Ruling
The Supreme Court modified the decision of the RTC. The appellant was found guilty beyond reasonable doubt of HOMICIDE, not murder. The death penalty was set aside, and the appellant was sentenced to suffer imprisonment for an indeterminate period. The awards for consequential and moral damages were modified, and temperate damages were awarded.
Ratio Decidendi
On the issue of appellant's guilt and the crime committed: The Court affirmed the positive identification of the appellant by the prosecution witnesses. The defense of frame-up was rejected. The Court found sufficient evidence to sustain the conviction for stabbing to death Rosemarie Reinante. However, the Court disagreed that treachery was proved, thus the crime was qualified as homicide, not murder. On the qualifying circumstance of treachery: The Court reiterated that treachery must be proved as sufficiently as the crime itself and cannot be presumed. It requires that the victim was not in a position to defend herself and that the accused consciously adopted the means to ensure execution without risk. The eyewitness testimony indicated that the victim tried to run away and was chased, and that there were heated arguments prior to the stabbing. This negated the element of surprise and the victim's inability to anticipate the aggression. Thus, treachery was not sufficiently established. On aggravating and alternative circumstances: The Court found that the generic aggravating circumstance of disregard of sex could not be considered as there was no showing of a manifest disrespect for the victim's gender. The alternative circumstance of intoxication was also not proven with certainty to have been a source of bravado or to have affected the appellant's mental faculties. Furthermore, even if present, these circumstances were not alleged in the information, and under the amended rules, such allegations are mandatory for their appreciation. On the penalty imposed: Since treachery was not proven, the crime was homicide, not murder. The penalty for homicide is reclusion temporal in its medium period. With no aggravating or mitigating circumstances, the penalty was imposed in its medium period. Applying the Indeterminate Sentence Law, the appellant was sentenced to an indeterminate period. On the award of damages: The award of consequential damages of ₱500,000 was deleted for lack of factual basis. The civil indemnity was fixed at ₱50,000. The moral damages were reduced from ₱100,000 to ₱50,000. Additionally, ₱25,000 was awarded as temperate damages because the victim's family suffered pecuniary loss, the amount of which could not be proved with certainty.
Main Doctrine
The qualifying circumstance of treachery must be proven as sufficiently as the crime itself and cannot be presumed. For treachery to be considered, the prosecution must show that at the time of the attack, the victim was not in a position to defend herself, and the accused consciously adopted the particular means, method, or form of attack employed. A prior argument or quarrel preceding the killing negates treachery as the victim may have been forewarned. Furthermore, aggravating and alternative circumstances must be alleged in the information to be appreciated.