GR 175602; (January, 2012) (Digest)
G.R. No. 175602; January 18, 2012
People of the Philippines, Plaintiff-Appellee, vs. PO2 Eduardo Valdez and Edwin Valdez, Accused-Appellants.
FACTS
Accused-appellants PO2 Eduardo Valdez and Edwin Valdez were charged with three counts of Murder for the killing of Ferdinand Sayson, Moises Sayson, Jr., and Joselito Sayson on March 1, 2000, in Quezon City. The Regional Trial Court convicted them of three counts of murder and sentenced them to reclusion perpetua for each count. The Court of Appeals affirmed the conviction with modifications to the damages. Edwin Valdez later withdrew his appeal, leaving only PO2 Eduardo Valdez’s appeal for resolution. The prosecution’s evidence, as summarized by the OSG, established that during a family celebration, the Valdez brothers arrived, armed, and after a confrontation with Moises Sayson, shot and killed Moises, Ferdinand, and Joselito Sayson. The defense version claimed the victims were the aggressors, with Moises blocking and poking a gun at Edwin, and Joselito and Ferdinand assaulting Eduardo, leading to a shootout where Joselito was accidentally hit by Ferdinand.
ISSUE
The primary issue is whether the Informations sufficiently alleged the qualifying circumstance of treachery to convict the accused of Murder.
RULING
The Supreme Court AFFIRMED the convictions but MODIFIED the crime from Murder to Homicide for each count. The Court held that while the killing was proven, the Informations failed to allege the facts and circumstances constituting the element of treachery. The Informations merely stated the killings were “qualified with treachery, evident premeditation and abuse of superior strength” without describing the manner of execution. Citing jurisprudence, the Court ruled that such a bare allegation is a conclusion of law, not a statement of fact, and is insufficient to inform the accused of the nature of the accusation against him. Consequently, the qualifying circumstance of treachery could not be appreciated. With treachery not established, the crimes committed were Homicide, not Murder. The Court upheld the finding of conspiracy based on the accused’s coordinated actions. PO2 Eduardo Valdez was found guilty of three counts of Homicide and sentenced to an indeterminate penalty for each count. The awards of damages were modified in accordance with prevailing jurisprudence.