People v. Cawayan
REITERATIONFacts
The Antecedents: On February 28, 1996, around 9:00 in the evening, the accused Edgar Cawayan y Cruz was with friends drinking beer. The group was playing cards. Around 12:30 in the morning, the accused returned, approached the group, and without warning, shot Christopher Carreon at the back while Carreon was lying face down. As Carreon pleaded for his life and attempted to stand, the accused uttered words indicating prior anger and shot him again in the stomach. The accused then fled. Procedural History: The Regional Trial Court, Cebu City, Branch 14, found the accused Edgar Cawayan y Cruz guilty beyond reasonable doubt of murder, sentencing him to reclusion perpetua and to pay P50,000.00 to the heirs of the offended party. The Petition: The accused appealed the decision of the RTC.
Issue(s)
Whether the accused is guilty beyond reasonable doubt of the crime of murder. Whether treachery and evident premeditation were present in the commission of the crime.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused guilty beyond reasonable doubt of murder and sentencing him to reclusion perpetua.
Ratio Decidendi
On the guilt of the accused for murder: The Court found that the prosecution had established the guilt of the accused beyond reasonable doubt. The eyewitness testimonies of Maricris Villan and Vilma Barrientos corroborated each other, detailing the sequence of events, including the accused's unprovoked attack on the victim. The post-mortem examination confirmed that the victim sustained two gunshot wounds, one at the back and another on the thoracic region, which were the direct cause of death. The accused's act of shooting the victim twice, once at the back and again while the victim was pleading for his life, demonstrated the intent to kill. On the presence of treachery and evident premeditation: The Court ruled that treachery was present. The attack was sudden and unexpected, with the victim lying face down and unable to defend himself when he was shot at the back. The second shot, fired while the victim was already wounded and pleading, further solidified the presence of treachery, as it ensured the commission of the crime without risk to the assailant. Regarding evident premeditation, the Court considered the accused's statement, "ganina na ko naglagot nimo (why should I not do it? I have been angry with you for a time)," which indicated a prior resolve to commit the offense. This statement, coupled with the time elapsed between the initial confrontation and the fatal shots, supported the finding of evident premeditation. The deliberate intent to kill was evident from the use of a firearm and the multiple shots fired at vital parts of the victim's body.
Main Doctrine
The presence of treachery and evident premeditation, coupled with the commission of murder, warrants the imposition of the penalty of reclusion perpetua.