G.R. No. 198954 February 22, 2017
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. RODRIGO MACASPAC y ISIP, Accused-Appellant

FACTS

On July 7, 1988, accused-appellant Rodrigo Macaspac was drinking with the victim, Robert Jebulan, and others in Caloocan City. A heated argument ensued between Macaspac and Jebulan, prompting Macaspac to utter threats, leave the scene, and return minutes later armed with a kitchen knife. He confronted Jebulan, who replied “Tama na,” before Macaspac suddenly stabbed him in the chest, causing his death. The case was archived for over 15 years until Macaspac’s arrest in 2004. At trial, Macaspac initially claimed self-defense, testifying he and Jebulan scuffled for the knife. He later changed his testimony, alleging Jebulan accidentally fell on the knife after being struck with a chair. The Regional Trial Court convicted him of murder qualified by treachery and sentenced him to reclusion perpetua, a decision affirmed by the Court of Appeals with modifications to civil liabilities.

ISSUE

Whether the qualifying circumstances of treachery and evident premeditation attended the killing to justify a conviction for murder.

RULING

The Supreme Court modified the conviction from murder to homicide. The Court upheld the lower courts’ factual findings and credibility assessments, rejecting Macaspac’s inconsistent claims of self-defense and accident. However, it ruled that the qualifying circumstances were not proven. Treachery requires the employment of means of execution that ensure the safety of the assailant from any defense the victim may make, without the victim being forewarned. Here, the preceding heated argument and Macaspac’s explicit threats alerted Jebulan to a possible attack, negating the element of surprise. Evident premeditation requires proof of the time when the offender determined to commit the crime, an act manifestly indicating this determination, and a sufficient lapse of time between the decision and execution to reflect upon the consequences. Macaspac’s act of leaving and returning with a knife within minutes showed a resolve immediately executed, which is insufficient for evident premeditation. Absent these qualifiers, the crime is homicide. Applying the Indeterminate Sentence Law, the penalty was reduced to an indeterminate sentence of eight years and one day of prision mayor as minimum, to fourteen years, eight months, and one day of reclusion temporal as maximum. Civil indemnity, moral damages, exemplary damages, and temperate damages were awarded, with legal interest.