G.R. No. 128812 February 28, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. THADEOS ENGUITO, defendant-appellant.

FACTS

In the early dawn of September 22, 1991, at Marcos Bridge in Cagayan de Oro City, accused-appellant Thadeos Enguito, driving a white vehicle, chased and intentionally bumped a motorela driven by Felipe Requerme, which was carrying his wife Rosita and passenger Wilfredo Achumbre. The violent impact and continued pushing caused the motorela to travel uncontrollably for about 400 meters before overturning. Achumbre jumped out and fled, but Enguito pursued him, ramming him with his vehicle while Achumbre was at the bridge railing, severing his leg and causing his instantaneous death. The Requerme spouses sustained injuries.
The defense, while not contesting the factual findings of the trial court, argued that Enguito acted in a state of shock and self-preservation. He claimed he was earlier attacked and stabbed by Achumbre and two others at a nightclub, and that he was merely fleeing his assailants when the collision with the motorela occurred. He asserted he had no knowledge of hitting Achumbre on the bridge due to his impaired condition from the attack.

ISSUE

Whether the Court of Appeals correctly affirmed the conviction of Thadeos Enguito for the complex crime of Murder with Less Serious Physical Injuries.

RULING

Yes, the conviction is affirmed. The Supreme Court upheld the finding of guilt beyond reasonable doubt. The defense of uncontrollable fear or force majeure was rejected. For this defense to prosper, the fear must arise from an immediate and imminent danger, and the reaction must be reasonable. The Court found Enguito’s actions disproportionate and unreasonable. After the initial alleged stabbing incident, the danger had ceased, as he was already inside his vehicle and driving away. His deliberate act of chasing, bumping the motorela over a long distance, and specifically pursuing Achumbre to ram him on the bridge constituted a deliberate and aggressive attack, not a reflexive act of self-preservation.
The qualifying circumstance of treachery was correctly appreciated. The attack on Achumbre was sudden and deliberate, executed in a manner that deprived him of any opportunity to defend himself or escape, especially as he was trapped at the bridge railing. The crime was properly classified as a complex crime under Article 48 of the Revised Penal Code, as the single act of using his vehicle resulted in both the murder of Achumbre and the less serious physical injuries to the Requerme spouses. The penalty for the most serious offense, murder, which is reclusion perpetua to death, was imposed in its maximum period, which is death. However, pursuant to the Constitution, this was reduced to reclusion perpetua. The civil indemnity awarded to Achumbre’s heirs was modified to P50,000.00, and moral damages were awarded to the Requerme spouses.