G.R. No. 131837-38 April 2, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. C2C RODNEY T. DUMALAHAY, et al., accused. C2C RODNEY T. DUMALAHAY, accused-appellant.

FACTS

Accused-appellant Rodney Dumalahay, along with Allan Halasan and Remegio Fuentes, were charged with two counts of Murder for the killings of Geronimo Layagon and Antonio Escalante on December 18, 1985. The information alleged that the victims, who had engaged Dumalahay to procure a firearm, were shot inside a moving Toyota Hi-Lux vehicle driven by Dumalahay, with Halasan firing an M-16 Armalite rifle. A fourth accused, Sgt. Roy Halasan, was charged as an accessory for towing the getaway vehicle. The Regional Trial Court convicted the principals and imposed the death penalty for each count of murder.
The prosecution’s case was built primarily on the extrajudicial confessions of the three principal accused, which detailed a conspiracy to kill the victims. Dumalahay, a PC constable, had promised to sell a firearm to Layagon and Escalante. After collecting money from them, he orchestrated their murder, instructing Halasan to shoot them inside the vehicle upon a pre-arranged signal. After the shooting, the vehicle stalled and was towed by Sgt. Roy Halasan. The bodies were later dumped.

ISSUE

The core issue for the Supreme Court’s review was the propriety of the penalty imposed—specifically, whether the death penalty was correctly applied.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the finding of guilt based on the credible and corroborated extrajudicial confessions, which established conspiracy and the qualifying circumstance of treachery. The victims were shot inside a moving vehicle, unable to defend themselves, ensuring the execution of the crime without risk to the perpetrators.
However, the Court reduced the penalty from death to reclusion perpetua for each murder. The crimes were committed in 1985 when the death penalty was abolished under the 1973 Constitution. Although the death penalty was reinstated by Republic Act No. 7659, which took effect on December 31, 1993, and was in force at the time the trial court rendered its judgment in 1997, the Court applied the constitutional rule that penal laws shall have prospective application unless favorable to the accused. Following the precedent in People v. Muñoz, the accused are entitled to the benefit of the more lenient law at the time of the commission of the offense. Therefore, the penalty imposable was reclusion perpetua, the supreme penalty under the 1987 Constitution at the time of the crimes.
The Court also modified the award of damages. It affirmed the awards of P50,000 as civil indemnity and P50,000 as moral damages for each victim, which require no proof other than death. Exemplary damages of P20,000 for each victim were also awarded due to the presence of aggravating circumstances. The civil liability of the accused-principals was declared solidary.