GR 137268; (March, 2001) (Digest)
G.R. No. 137268; March 26, 2001
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EUTIQUIA CARMEN @ Mother Perpetuala, et al., accused-appellants.
FACTS
Accused-appellants, led by Eutiquia Carmen (Mother Perpetuala), were charged with murder for the death of 13-year-old Randy Luntayao. The prosecution evidence established that the victim’s father, Eddie Luntayao, brought Randy to appellants for a healing ritual, believing the boy was ill. Appellants, claiming the boy was possessed, isolated him from his parents. Child eyewitness Honey Fe Abella testified she saw appellants submerge Randy’s head in a drum of water, tie him to a bench, force him to drink water, pound his chest, sit on him, and finally, Carmen stabbed him with a knife. Eddie Luntayao testified he heard his son cry for help but was locked in a room. Randy’s body was later presented, showing he was dead. Appellants then arranged for a death certificate citing “bronchial asthma” as the cause.
The Regional Trial Court convicted all accused-appellants of murder qualified by treachery and sentenced them to reclusion perpetua. On appeal, appellants argued the prosecution failed to prove the cause of death and their intent to kill, claiming they only performed a healing ritual.
ISSUE
Whether the accused-appellants are guilty of murder, or if their criminal liability should be for a lesser offense.
RULING
The Supreme Court modified the conviction from murder to reckless imprudence resulting in homicide. The Court found that the prosecution successfully proved appellants inflicted fatal injuries on the victim, as corroborated by the eyewitness and the father’s testimony. However, the element of intent to kill required for murder was not established beyond reasonable doubt. The evidence showed appellants acted under the misguided belief they were exorcising an evil spirit, not with a deliberate design to kill. Their actions—submersion, physical beating, and stabbing—constituted gross negligence and reckless disregard for the victim’s life and safety. The killing was thus a result of imprudence, not a deliberate attack. The qualifying circumstance of treachery was also absent, as the means employed did not deliberately ensure the execution without risk to the appellants. Consequently, appellants are guilty of the lesser crime of reckless imprudence resulting in homicide. The Court affirmed the civil indemnity and awarded moral and exemplary damages.