People v. Adriano
REITERATIONFacts
The Antecedents: Accused-appellant Rolly Adriano y Samson was convicted of Homicide for the killing of Ofelia Bulanan and Murder for the killing of Danilo Cabiedes. The prosecution presented evidence that on March 13, 2007, at around 8:00 a.m., in Malapit, San Isidro, Nueva Ecija, four armed men alighted from a speeding Toyota Corolla, shot the driver of a Honda CRV (identified as Cabiedes), and fled. Bulanan, a bystander, was hit by a stray bullet and died. Cabiedes also died from multiple gunshot wounds. PO1 Matthew Garabiles and PO2 Alejandro Santos, who were on a motorcycle nearby, witnessed the incident and later identified Adriano as one of the assailants. Adriano was arrested when he returned the rented Corolla to its owner, who confirmed Adriano was the lessee. Procedural History: The Regional Trial Court (RTC) convicted Adriano of Murder for Cabiedes' death and Homicide for Bulanan's death, rejecting his alibi. The Court of Appeals (CA) affirmed the RTC's decision, modifying the award of civil indemnity. The RTC awarded ₱50,000.00 civil indemnity and ₱222,482.00 actual damages for Cabiedes' heirs, and ₱50,000.00 civil indemnity for Bulanan's heirs. The CA increased the civil indemnity for Cabiedes to ₱75,000.00 and awarded ₱75,000.00 moral damages to Cabiedes' heirs and ₱50,000.00 moral damages to Bulanan's heirs. The Petition: Adriano appealed his conviction, arguing that the RTC erred in not appreciating his defense of alibi and the testimonies of his witnesses, and that the prosecution witnesses' testimonies were inconsistent.
Issue(s)
Whether the accused-appellant is guilty of Murder for the death of Danilo Cabiedes. Whether the accused-appellant is guilty of Homicide (or Murder) for the death of Ofelia Bulanan under the doctrine of aberratio ictus. Whether the defense of alibi was properly rejected. Whether the prosecution witnesses' testimonies were credible despite alleged inconsistencies.
Ruling
The Supreme Court affirmed the Court of Appeals' decision with modifications, finding accused-appellant Rolly Adriano y Samson guilty beyond reasonable doubt of two counts of Murder. He was sentenced to suffer the penalty of reclusion perpetua for the killing of Danilo Cabiedes and for the killing of Ofelia Bulanan. Monetary awards were also modified.
Ratio Decidendi
On the guilt for the death of Danilo Cabiedes: The Court found that the elements of murder were established. The death of Cabiedes was proven, and Adriano was positively identified as one of the perpetrators. The Court held that treachery was present, as the attack was sudden and unexpected, depriving Cabiedes of any chance to defend himself. The assailants ambushed Cabiedes, firing multiple shots and immediately fleeing, ensuring the commission of the crime without risk to themselves. The Court noted that the abuse of superior strength was absorbed by treachery. The Court reiterated that for treachery to be appreciated, the victim must be defenseless at the time of the attack, and the accused must have consciously adopted means to ensure the execution of the crime without risk. The orchestrated ambush and the subsequent flight demonstrated a deliberate plan to kill Cabiedes without risk of retaliation. On the guilt for the death of Ofelia Bulanan: The Court ruled that Adriano is guilty of Murder for Bulanan's death under the doctrine of aberratio ictus (stray bullet). Although Bulanan was a bystander and her death was not intended, it was a natural and logical consequence of Adriano's felonious act of shooting at Cabiedes. The Court cited Article 4 of the Revised Penal Code, which states that criminal liability is incurred for all natural and logical consequences of a wrongful act, even if unforeseen or unintended. The Court applied the ruling in People v. Flora, where treachery was appreciated in a case involving aberratio ictus, qualifying both the intended victim's death and the bystander's death to murder. The Court emphasized that the fact that the accused killed a person other than the intended victim does not exculpate him from responsibility for the consequences of his felonious act. On the rejection of the defense of alibi: The Court affirmed the RTC and CA's rejection of Adriano's alibi. The Court reiterated that alibi is an inherently weak defense that can easily be fabricated and requires convincing proof of physical impossibility to be at the crime scene. Adriano claimed to be in Dolores, Magalang, Pampanga, which is less than an hour away from the crime scene in San Isidro, Nueva Ecija. This proximity made it physically possible for him to have been present at the crime scene. Furthermore, his alibi was corroborated by his relatives and friends, which the Court held is not as credible as positive identification by prosecution witnesses. On the credibility of prosecution witnesses: The Court found the prosecution witnesses' testimonies to be credible. While Adriano alleged minor inconsistencies in their accounts regarding the sequence of events, the identity of the shooter, and the distance of the vehicles, the Court held that such minor discrepancies do not impair the witnesses' credibility. Instead, the Court noted that minor variations in testimony can be signs of veracity, as they indicate that the witnesses were not coached. The positive identification of Adriano by PO1 Garabiles and PO2 Santos as one of the assailants who alighted from the Corolla and shot Cabiedes was given full credence.
Main Doctrine
The doctrine of aberratio ictus applies even when the death of a bystander is caused by a stray bullet, making the offender liable for murder if the attack on the intended victim was qualified by treachery. Minor inconsistencies in the testimonies of prosecution witnesses, when positive in their identification of the accused, do not necessarily impair their credibility.