G.R. No. L-48744 October 30, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FRANCISCO CENTENO, JUAN CENTENO alias Totok, MANUEL CENTENO alias Iyao, accused-appellants.

FACTS

The accused-appellants, Francisco, Juan, and Manuel Centeno, were charged with Murder before the Court of First Instance of Iloilo. The trial court, however, found them guilty only of simple homicide, appreciating the mitigating circumstance of voluntary surrender. It sentenced each to an indeterminate penalty ranging from six years, eight months, and one day of prision mayor to fifteen years, six months, and twenty-one days of reclusion temporal. On appeal, the Court of Appeals did not affirm or modify this judgment. Instead, it adopted the Solicitor General’s view that the crime committed was Murder, qualified by treachery and aggravated by evident premeditation, warranting the penalty of either life imprisonment or death. Refraining from imposing either penalty, the appellate court certified the case to the Supreme Court for final determination, citing Section 34 of the Judiciary Act and Section 12, Rule 124 of the Rules of Court.

ISSUE

Whether the Court of Appeals, in a case appealed to it where the imposable penalty is death or reclusion perpetua, should render a judgment expressly imposing such penalty before certification to the Supreme Court, or should it simply certify the case without entering judgment?

RULING

The Supreme Court ruled to return the case to the Court of Appeals for it to render judgment imposing the proper penalty, in accordance with the doctrine established in People vs. Daniel. The Court reiterated its directive that when the Court of Appeals, in an appealed criminal case where the trial court imposed a penalty lower than reclusion perpetua, concludes that the penalty of death or reclusion perpetua should be imposed, it must render a comprehensive judgment expressly and explicitly imposing the appropriate penalty. It must then refrain from entering that judgment and forthwith certify the entire record to the Supreme Court for review. This procedure was mandated to correct the old practice of mere certification without a definitive appellate ruling on the penalty. The resolution acknowledges a separate opinion within the Court questioning the Daniel doctrine’s practicality, suggesting that the old practice of certification without a full judgment might be more efficient, especially where the penalty is life imprisonment and immediate execution could be sought. However, the majority view, as controlling precedent, requires the Court of Appeals to perform its own complete evaluation and imposition of penalty before certification.