G.R. No. L-76954-55 February 26, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BENIANO RENEJANE, IRENEO NICK LABORTE, BENJAMIN PURISIMA, PAULINO LABORTE, LORETO BACUS and RODOLFO RIPDOS, accused-appellants.

FACTS

The accused-appellant Beniano Renejane, along with five others, was charged with two counts of murder for the killings of Mario de Jesus and Regino Mara-asin on November 1, 1981, in Balamban, Cebu. The prosecution’s case relied heavily on the eyewitness account of Pablo Sumandig. He testified that after a series of drinking sessions in different houses, an altercation occurred between Renejane and Patrolman Mario de Jesus concerning marijuana. Following this, Paulino Laborte drew a knife and stabbed de Jesus. Sumandig then saw Beniano Renejane make the second stabbing attack on de Jesus. He also witnessed the stabbing of Regino Mara-asin, though he could not initially name the assailant, later implicating Renejane and others in the concerted attack.
The trial court found Renejane guilty beyond reasonable doubt of double murder. It appreciated the qualifying circumstance of treachery and several generic aggravating circumstances, including taking advantage of superior strength, employing means to weaken the victims by making them drunk, and deliberately inflicting unnecessary wounds after death. The court sentenced him to two penalties of reclusion perpetua and ordered him to pay indemnity to the victims’ heirs. Renejane appealed the decision.

ISSUE

The primary issue is whether the trial court correctly appreciated the circumstances surrounding the crime and properly imposed the penalty of reclusion perpetua for each count of murder.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the finding of treachery, as the attack was sudden and unexpected, rendering the victims defenseless. However, it corrected the trial court’s appreciation of aggravating circumstances. The Court ruled that abuse of superior strength is inherent in treachery and cannot be separately considered. The allegation of employing means to weaken the victims (making them drunk) was not proven as intentional or habitual intoxication, and thus not aggravating. Furthermore, the infliction of wounds after death did not constitute an aggravating circumstance of ignominy, as there was no evidence the acts were intended to outrage or scoff at the victims; they were merely a continuation of the intense attack.
With treachery as the sole qualifying circumstance and no other aggravating or mitigating circumstances, the prescribed penalty for murder is reclusion temporal in its maximum period to death. Applying the Indeterminate Sentence Law and following prevailing jurisprudence, the Court modified the penalty. For each murder, Renejane was sentenced to an indeterminate penalty ranging from seventeen years, four months, and one day of reclusion temporal maximum as a minimum, to reclusion perpetua as a maximum. The award of civil indemnity was affirmed. The decision was concurred in by the other justices.