GR L 69070; (November, 1984) (Digest)
G.R. No. L-69070-72 November 29, 1984
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LEONILA OGA-OGA, DOMINGO OGA-OGA, and JUANITO OGA-OGA @ JOHN, accused-appellants.
FACTS
Accused-appellants Domingo Oga-Oga, John Oga-Oga, and Leonila Oga-Oga were convicted by the Court of First Instance of Leyte of triple murder for the deaths of Alfredo, Anita, and Antonio Oga-Oga on April 1, 1981. The prosecution established a motive rooted in a tenancy dispute over a parcel of land in Leyte. The tenancy, previously held by John, was awarded to the victim-spouses Alfredo and Anita, which was resented by the appellants. The relationship was further strained by a pending defamation case filed by Leonila against Leticia, Antonio’s wife.
The prosecution’s eyewitnesses, Quirico Quinabo and Fructuoso Anota, testified that on the said date, while the victims were planting corn, the appellants arrived. Leonila engaged Anita in a heated argument. Subsequently, upon Leonila’s command, Domingo and John attacked and killed Anita, Alfredo, and Antonio one after the other, mutually helping each other. The trial court found the killings were qualified by abuse of superior strength.
ISSUE
The principal issue on appeal to the Supreme Court, concerning Leonila Oga-Oga, was the correctness of her conviction as a principal by inducement and the propriety of the penalty imposed.
RULING
The Supreme Court affirmed Leonila’s conviction. The Court found the evidence sufficient to establish her guilt as a principal by inducement. The factual findings of the trial court, as affirmed by the Intermediate Appellate Court, detailed her direct instigation of the attacks, which led to the coordinated killings by Domingo and John. The Court upheld the qualification of abuse of superior strength, as the two male accused, acting together upon Leonila’s inducement, employed their combined strength to overcome the three victims separately.
Regarding the penalty, the Court corrected the trial court’s error. The penalty for murder is reclusion temporal in its maximum period to death. With no modifying circumstances attending Leonila’s criminal liability, the applicable penalty is the medium period, which is reclusion perpetua. The Court emphasized that the Indeterminate Sentence Law does not apply to offenses punishable by reclusion perpetua. Consequently, the indeterminate sentence originally imposed was improper. Leonila Oga-Oga was sentenced to suffer three penalties of reclusion perpetua and to pay civil indemnity.