GR 132152; (January, 2000) (Digest)
G.R. No. 132152 January 19, 2000
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EUGENIO ADRALES and JESSIE PANAO, accused-appellants.
FACTS
The accused-appellants, Eugenio Adrales and Jessie Panao, were charged with Murder for the killing of Manuel Arizo on January 25, 1996, in Tunga, Leyte. The prosecution’s eyewitness, Jovencio Briones, testified that on the evening of the incident, the two appellants, who appeared intoxicated, were challenging people to a fight. They proceeded to the victim’s house, persistently called him out for a drink, and upon Manuel stepping outside, Panao pulled him while Adrales immediately stabbed him in the back with a small bolo. Panao then pushed the victim, causing him to fall. The victim’s wife, Salvacion Arizo, corroborated the events, stating the appellants kept shouting for her husband to come out before the sudden attack. The victim later died from his wounds.
The defense presented a different version, claiming they were all coming from a drinking session. They asserted that the victim became angry when Panao refused to give him money, leading the victim to assault Panao. Adrales claimed he intervened and stabbed the victim only to protect Panao from further harm. The Regional Trial Court convicted both appellants of Murder qualified by treachery and sentenced them to death, prompting this automatic review.
ISSUE
The core issue is whether the trial court correctly convicted the appellants of Murder and properly imposed the death penalty.
RULING
The Supreme Court affirmed the conviction for Murder but modified the penalty to reclusion perpetua. The Court found the testimonies of prosecution eyewitnesses Jovencio Briones and Salvacion Arizo to be credible, consistent, and sufficient to establish the appellants’ guilt beyond reasonable doubt. Their positive identification outweighed the appellants’ denial and alternative narrative.
On the qualifying circumstance, the Court upheld the finding of treachery. The attack was sudden and unexpected, executed in a manner that ensured the execution without risk to the appellants from any defense the unarmed victim could make. The victim was called out under the pretense of socializing, with no opportunity to defend himself when Adrales immediately stabbed him from behind upon his exit.
However, the Court ruled the trial court erred in imposing the death penalty. While the information alleged evident premeditation, the prosecution failed to prove its elements—proof of the time when the appellants determined to commit the crime, an act showing they clung to that determination, and a sufficient interval for reflection. With no aggravating circumstance proven, Article 63 of the Revised Penal Code mandates the application of the lesser penalty when the law prescribes two indivisible penalties (reclusion perpetua to death) and no mitigating or aggravating circumstances attend the crime. Consequently, the penalty was reduced to reclusion perpetua.