G.R. No. 118940 -41 and G.R. No. 119407 July 7, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GREGORIO MEJIA y VILLAFANIA, EDWIN BENITO, PEDRO PARAAN, and JOSEPH FABITO, accused-appellants.

FACTS

In the evening of 10 March 1994, along the expressway at Barangay Ventinilla, Sta. Barbara, Pangasinan, several persons on board a passenger jeepney driven by Teofilo Landingin attacked the latter and a passenger, Virgilio Catugas, inflicting multiple stab wounds. Landingin was pulled out and dumped on the shoulder of the road. One attacker took the wheel and drove the jeepney away. Catugas was thrown out to the middle of the road. Landingin died; Catugas survived. Accused Gregorio Mejia, Edwin Benito, Pedro Paraan, and Joseph Fabito, along with others (some at large, one found dead), were charged with Murder, Frustrated Murder, and violation of the Anti-Carnapping Act. The cases for Murder and Frustrated Murder were consolidated in Branch 44 (Judge Laron), while the Carnapping case was in Branch 43 (Judge Castillo). The accused pleaded not guilty. The prosecution’s evidence, primarily from victim Virgilio Catugas, established that nine persons, including the four accused, boarded the jeepney, announced a hold-up, and stabbed Landingin and Catugas. Catugas identified the accused. Policemen testified to apprehending Mejia and Benito, and later Fabito, and recovering the bloodstained jeepney. The defense claimed it was their companion Romulo Calimquim and others who committed the crimes. The trial courts convicted the accused. The Laron court found them guilty of Murder and Frustrated Murder, sentencing them to death for Murder and an indeterminate penalty for Frustrated Murder. The Castillo court found them guilty of Carnapping, sentencing them to reclusion perpetua. The cases were appealed to the Supreme Court.

ISSUE

The main issues involve the credibility of the prosecution witness Virgilio Catugas, the presence of qualifying circumstances for Murder, the propriety of the penalties imposed (including the death penalty), and the legal implications of the Carnapping conviction in relation to the killing.

RULING

The Supreme Court modified the decisions. It affirmed the convictions but modified the penalties and damages.
1. Credibility of Witness: The Court found Virgilio Catugas’ testimony credible, positive, and categorical. His identification of the accused was reliable as he had a clear view due to the jeepney’s interior light and his proximity. The defense of denial and alibi could not prevail over his positive identification.
2. Crime and Qualifying Circumstances: The killing of Teofilo Landingin constituted Murder qualified by treachery. The attack was sudden and unexpected, giving the victim no chance to defend himself. However, the Court found that the aggravating circumstances of evident premeditation and abuse of superior strength were not proven with equal certainty. For Frustrated Murder against Catugas, treachery was also present.
3. Penalties:
* For Murder ( G.R. No. 118940 ): The penalty under Article 248 of the Revised Penal Code, as amended by R.A. No. 7659 , is reclusion perpetua to death. With treachery as the sole qualifying circumstance and no mitigating or aggravating circumstances, the proper penalty is reclusion perpetua. The death penalty imposed by the trial court was reduced to reclusion perpetua.
* For Frustrated Murder (G.R. No. 118941): The penalty is one degree lower than that for Murder, which is reclusion temporal. Applying the Indeterminate Sentence Law, the accused were sentenced to an indeterminate penalty of ten (10) years of prision mayor, as minimum, to seventeen (17) years and four (4) months of reclusion temporal, as maximum.
* For Carnapping (G.R. No. 119407): The penalty under Section 14 of R.A. No. 6539 , as amended, when carnapping is committed with violence or intimidation and results in death, is “life imprisonment to death.” The trial court’s penalty of reclusion perpetua was affirmed, as “life imprisonment” is synonymous with reclusion perpetua under Philippine law. The Court clarified that the accused could be convicted separately for Carnapping and Murder, as the law punishes the act of carnapping itself and the resulting homicide as a single special complex crime, distinct from Murder under the Revised Penal Code.
4. Damages: The Court awarded civil indemnity, moral damages, and actual damages (for burial and medical expenses) to the victims’ heirs, and temperate damages to Catugas for unreceipted expenses.
The dispositive portion of the Supreme Court’s decision affirmed the convictions but modified the penalties: imposing reclusion perpetua for Murder, an indeterminate sentence for Frustrated Murder, and affirming reclusion perpetua for Carnapping, with corresponding damages.