G.R. No. L-36662-63 July 30, 1982
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FILOMENO CAMANO, defendant-appellant.

FACTS

The accused, Filomeno Camano, was charged with two counts of murder for the killings of Godofredo Pascua and Mariano Buenaflor on February 17, 1970, in Barrio Nato, Sagñay, Camarines Sur. The prosecution established that after drinking liquor, Camano first stabbed Pascua twice with a bolo, causing instant death, as the victim walked along a barrio street. Camano then proceeded to the seashore where he found Buenaflor leaning on a fence and hacked him multiple times, inflicting eight wounds, two of which were mortal, also causing instant death. The accused and victims were neighbors, and the incident was rooted in a three-year-old grudge stemming from the victims’ refusal to tow Camano’s fishing boat.
At trial, Camano admitted killing Buenaflor but claimed self-defense. He denied killing Pascua and downplayed the prior grudge. The trial court rejected the defenses, finding the killings were attended by treachery and evident premeditation, and imposed the death penalty for each crime. The case was elevated to the Supreme Court for automatic review.

ISSUE

Whether the trial court correctly convicted the accused of two counts of murder and properly appreciated the attendant circumstances, including the imposition of the death penalty.

RULING

The Supreme Court affirmed the conviction for murder but modified the penalty. The Court upheld the finding of treachery (alevosia) for both killings. The attack on Pascua was sudden and from behind, while the assault on Buenaflor commenced with a hack to the head while the victim was in a vulnerable, kneeling position, ensuring the execution without risk to the assailant. However, the Court found that evident premeditation was not sufficiently established. While a prior grudge existed, the prosecution failed to prove clear evidence of planning or a sufficient lapse of time between the resolution to kill and its execution.
The Court appreciated the mitigating circumstance of intoxication, as it was not habitual and diminished the accused’s discernment, and found no aggravating circumstances to offset it. Consequently, the proper penalty for each murder was the minimum period of reclusion temporal. Applying the Indeterminate Sentence Law, the Court modified the penalty to an indeterminate sentence of 10 years and 1 day of prision mayor as minimum to 17 years, 4 months, and 1 day of reclusion temporal as maximum for each count. The Court also rejected the constitutional challenge against the death penalty, citing precedent that it is not considered cruel or unusual punishment, but the penalty was reduced due to the presence of the mitigating circumstance.