GR L 47118; (May, 1984) (Digest)
G.R. No. L-47118 May 21, 1984
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JUAN LAGANZON, SEBASTIAN LAGANZON and ALEX CHALLOY, defendants-appellants.
FACTS
The accused, Juan Laganzon, Sebastian Laganzon, and Alex Challoy, were charged with murder for the death of Francisco Pega on January 31, 1962, in Bato, Camarines Sur. The prosecution’s evidence established that the victim was initially at a store where Juan Laganzon struck him. Later that evening, eyewitness Vitaliano Orasa saw all three accused together beating Pega with pieces of wood and bamboo beside a railway until he fell. Subsequently, Orasa witnessed Juan and Sebastian Laganzon carrying Pega’s body onto the railroad tracks, where he was later found run over by a train. The trial court convicted them of murder qualified by abuse of superior strength and imposed a penalty of 17 years, 4 months, and 1 day to 20 years of reclusion temporal. The Court of Appeals affirmed the guilt but found the proper penalty to be reclusion perpetua, certifying the case to the Supreme Court for final determination.
ISSUE
Whether the Court of Appeals correctly determined the proper penalty for the crime of murder committed by the appellants.
RULING
The Supreme Court affirmed the findings of guilt and the penalty imposed by the Court of Appeals. The legal logic is grounded in the proper application of the Revised Penal Code. Murder, under Article 248, is punishable by reclusion temporal maximum to death. The qualifying circumstance of abuse of superior strength was correctly appreciated, as the three armed accused conspired to overwhelm the single, unarmed victim. Under Article 64 of the Code, when a penalty has three periods and no mitigating or aggravating circumstances are present, the penalty shall be imposed in its medium period. Since the prescribed penalty for murder is reclusion temporal maximum to death, its medium period is reclusion perpetua. The trial court erred in imposing a lesser penalty within the range of reclusion temporal. The Supreme Court thus modified the penalty to reclusion perpetua for the living appellants and increased the civil indemnity to P30,000. The Court also dismissed the criminal case against Sebastian Laganzon due to his supervening death, which extinguished his personal criminal liability.