GR 37162; (May, 1978) (Digest)
G.R. No. L-37162 May 30, 1978
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WARLITO PLATEROS Y CALATRAVA, alias BABIE, and MURILLO LAHOY Y BUENO, alias BOY, defendants-appellants.
FACTS
The appellants, Warlito Plateros and Murillo Lahoy, were convicted by the Court of First Instance of Bohol for the murder of Pedro Candel (Criminal Case No. 566) and sentenced to reclusion perpetua. In a joint trial, Lahoy was also convicted of the attempted murder of Tomas Metucua (Criminal Case No. 567), while Plateros was acquitted of that charge. Lahoy appealed the attempted murder conviction to the Court of Appeals, which subsequently acquitted him. Plateros, in his appeal to the Supreme Court in the murder case, brought this acquittal to the Court’s attention. The murder arose from a nighttime attack on a pedicab, driven by Candel and carrying Metucua, outside a kitchenette. The prosecution evidence established that Plateros, motivated by jealousy over Estrella Silmaro’s affection for Metucua, conspired with Lahoy to attack Metucua.
ISSUE
The primary procedural issue was whether the Court of Appeals had jurisdiction to decide Lahoy’s appeal in the attempted murder case, given that it arose from the same occurrence as the murder case pending before the Supreme Court. The substantive issue was whether the appellants’ guilt for the murder of Pedro Candel was proven beyond reasonable doubt.
RULING
On the jurisdictional issue, the Supreme Court held that under Section 17(1) of the Judiciary Law, the Court of Appeals generally should have certified Lahoy’s attempted murder appeal to the Supreme Court, as it arose from the same occurrence as the murder case. However, the Court applied the exception established in People vs. Carillo, which states that certification is unnecessary if no conflict between the decisions of the two courts is possible. Since the victims in the two cases were different (Candel for murder, Metucua for attempted murder), Lahoy’s acquittal for wounding Metucua would not affect the determination of his guilt for killing Candel. Therefore, the Supreme Court declined to disturb the Court of Appeals’ acquittal.
On the merits of the murder case, the Supreme Court affirmed the conviction. It upheld the trial court’s assessment of the prosecution witnesses as credible and rejected the appellants’ alibi as flimsy. The Court found that the killing was attended by treachery (alevosia), qualifying it as murder. The appellants, who had been together for hours, waited for the victims to leave the kitchenette before launching a sudden and unexpected attack with bolos, ensuring no risk to themselves. The Court explained the killing of Candel, instead of the intended victim Metucua, as an aberratio ictus (mistake in the blow), likely due to the darkness and the appellants’ intoxication, as they mistakenly assumed the persons seated in the pedicab. The penalty of reclusion perpetua was affirmed, with no mitigating circumstances appreciated.