G.R. No. 153591; February 23, 2004
PEOPLE OF THE PHILIPPINES, appellee vs. RENATO GARCIA y ROMANO, appellant.

FACTS

Appellant Renato Garcia was charged with Murder for an incident on May 22, 1998. The prosecution alleged that while driving a passenger jeepney along Zabarte Road in Quezon City, he initially hit pedestrian Sanily Billon, causing her to fall. After the vehicle stopped, it suddenly accelerated, and its front tire ran over Sanily’s stomach. She was rushed to the hospital but died four days later from internal injuries caused by blunt force. The victim’s brother, Bentley, testified to this sequence of events. Appellant admitted the incident but claimed it was purely accidental, stating he heard a thud, stopped, and only then discovered the victim under his vehicle.
The Regional Trial Court convicted appellant of Murder, qualified by evident premeditation, and sentenced him to reclusion perpetua. The trial court held that the act of deliberately running over the victim after the initial impact demonstrated premeditation. Appellant appealed, arguing the prosecution failed to prove evident premeditation and that the facts support a conviction only for reckless imprudence.

ISSUE

Whether the trial court erred in convicting appellant of Murder qualified by evident premeditation instead of reckless imprudence resulting in homicide.

RULING

The Supreme Court reversed the trial court’s decision. It found that the qualifying circumstance of evident premeditation was not proven beyond reasonable doubt. The essential elements of evident premeditation—a prior decision to commit the crime, overt acts showing persistence, and sufficient lapse of time for reflection—were absent. The testimony indicated the vehicle moved forward shortly after the initial impact, with no sufficient interval for appellant to coolly reflect and form a deliberate intent to kill. The prosecution failed to establish any prior plan or motive.
Consequently, the Court ruled the act constituted reckless imprudence resulting in homicide under Article 365 of the Revised Penal Code. Appellant’s negligent operation of the vehicle, which caused the victim’s death, was established. The penalty was modified to an indeterminate sentence of four months and one day of arresto mayor, as minimum, to four years and two months of prision correccional, as maximum. The awards for damages were also adjusted: civil indemnity of P50,000.00, actual damages of P58,257.90, and moral damages of P50,000.00 were upheld, while exemplary damages were deleted.