Facts: On April 29, 1991, at around 4:00 PM in Tuao, Cagayan, Ceferino Dagulo was chopping firewood when he heard the shouts of a woman and a child from the north. Gerardo Latupan y Sibal, armed with a bloody knife, approached and attempted to assault Ceferino, who managed to deflect the attack. Latupan, covered in blood, threatened to kill everyone and attempted to hand over his weapon to Ceferino. Ceferino advised him to surrender to the authorities, prompting Latupan to flee.
Meanwhile, Emilio Asuncion discovered multiple tragedies. Upon returning home, he found his wife, Lilia Asuncion, dead with stab wounds. His young son, Leo, was injured, and his eldest child, Jose, was severely wounded and required immediate medical attention. Jose identified Latupan as the assailant. While being transported with the family to the hospital by military personnel, Jose succumbed to his injuries.
On April 13, 1992, Prosecutor Alejandro A. Pulido filed charges against Latupan for two counts of murder for the deaths of Lilia and Jose Asuncion, and two counts of frustrated murder for the injuries caused to Jaime and Leo Asuncion. The trial court initially arraigned Latupan, where he pleaded not guilty but later changed his plea, admitting guilt to complex crimes. The court accepted this change and heard testimonies.
During the proceedings, crucial evidence was presented, notably the testimony of young Jaime Asuncion, who confirmed the brutal actions of Latupan, who knew the family personally.
Procedural Posture: After Latupan’s guilty plea, the Regional Trial Court convicted him of the complex crime of double murder and physical injuries, sentencing him to life imprisonment and ordering indemnities for the victims’ families. Latupan appealed to the Supreme Court, asserting errors in the trial court’s judgment.
Issues:
1. Whether the trial court erred in convicting for a complex crime of double murder.
2. Whether the sentence of “life imprisonment” was appropriate under the Revised Penal Code.
3. Whether the aggravating circumstance of evident premeditation was correctly applied.
Court’s Decision:
1. **Complex Crime Issue**: The Supreme Court held that the deaths of Lilia and Jose Asuncion and injuries to Jaime and Leo resulted from separate acts, rejecting the notion of a complex crime. Convictions were adjusted to two separate counts of murder and counts of slight physical injuries.
2. **Sentence Appropriateness**: The Supreme Court corrected the “life imprisonment” penalty to “reclusion perpetua” as required by the Revised Penal Code. It emphasized that these penalties are significantly different in legal implications and accessory penalties.
3. **Evident Premeditation**: The trial court incorrectly considered evident premeditation without sufficient proof. The record lacked evidence showing deliberate planning, thus should not have been used to enhance the penalty.
Doctrine: The case reinforced that multiple offenses resulting from distinct acts should not be treated as complex crimes unless arising from a single act, as per Article 48 of the Revised Penal Code. It clarified the penalty distinction between “life imprisonment” and “reclusion perpetua,” and reasserted the need for evidence to apply aggravating circumstances.
Class Notes:
– **Murder Elements**: Intent to kill, treachery, direct participation. Absence of a single act in multiple killings leads to separate charges.
– **Penalties**: “Reclusion perpetua” vs. “Life imprisonment” – Reclusion perpetua has accessory penalties, defined duration.
– **Evident Premeditation**: Requires clear evidence of planning. Cannot be presumptuous.
Statutory Citations:
– **Article 48**, Revised Penal Code: Complex crimes defined.
– **Article 248**, Revised Penal Code: Murder penalties stipulation.
Moral Damages: P50,000 per deceased as moral damages without proving suffering.
Historical Background: This case unfolded during the early 1990s in the Philippines, a period marked by various legal refinements in criminal jurisprudence. The judgment exemplifies the judiciary’s adaptability in interpreting and enforcing justice, ensuring correct applications of penalties conforming to the Revised Penal Code, reflecting the legal evolution in response to criminal actions and their consequences.
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