GR 91162; (October, 1991) (Digest)
G.R. No. 91162 October 3, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO CARAIG y FELIX, accused-appellant.
FACTS
Accused-appellant Reynaldo Caraig was charged with Murder for the killing of Armando Villena on January 19, 1981, in Manila. The prosecution presented eyewitness Lucy Dalay, who testified that around 1:00 AM, she saw Caraig stab Villena twice with a kitchen knife while the victim pleaded for his life. She claimed a clear view from about 2.5 meters away in a well-lit area. Another witness, Petronila Quintero, testified to prior events, stating that Caraig had earlier confronted Villena at her house while concealing a knife, indicating a pre-existing grudge. The medico-legal report indicated Villena suffered nine stab wounds, some fatal, possibly inflicted by more than one instrument. The trial court convicted Caraig of Murder qualified by evident premeditation and sentenced him to life imprisonment.
ISSUE
Whether the trial court erred in convicting the accused-appellant of Murder, specifically in finding the qualifying circumstance of evident premeditation to be present.
RULING
The Supreme Court modified the conviction from Murder to Homicide. The Court affirmed the factual findings of the trial court regarding the appellant’s identity as the assailant, upholding the credibility of eyewitness Lucy Dalay. Her testimony was found clear and consistent, and her delay in reporting was sufficiently explained. However, the Court ruled that the qualifying circumstance of evident premeditation was not proven beyond reasonable doubt. For evident premeditation to qualify a killing as murder, the prosecution must prove: (a) the time the offender determined to commit the crime; (b) an act showing he clung to his determination; and (c) a sufficient lapse of time between determination and execution to allow reflection. Here, while prior animosity between the appellant and the victim was established, there was no direct evidence of the specific time the plan to kill was conceived or of the planning and preparation. Mere existence of a grudge is insufficient to infer evident premeditation. Consequently, the killing constituted Homicide under Article 249 of the Revised Penal Code. The penalty was modified to an indeterminate sentence of 8 years and 1 day of prision mayor as minimum, to 14 years, 8 months, and 1 day of reclusion temporal as maximum. The civil indemnity was increased to P50,000.00.