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PEOPLE v. ROLLY ADRIANO Y SAMSON

FACTS:

On March 13, 2007, a blue Toyota Corolla overtook a maroon Honda CRV along Olongapo-Gapan National Road. The passenger in the Corolla shot at the CRV, causing it to swerve and fall into a canal. Four armed men then shot the driver of the CRV, Danilo Cabiedes. A bystander named Ofelia Bulanan was hit by a stray bullet and both Cabiedes and Bulanan died from their injuries. The Corolla was registered under Antonio Rivera's name and was leased to the accused, Rolly Adriano. Adriano was arrested and charged with two counts of murder. He pleaded not guilty and presented an alibi defense but was convicted by the Regional Trial Court (RTC). The Court of Appeals affirmed the conviction.

The RTC rejected Adriano's alibi defense, considering it unsupported by clear and convincing evidence. The court relied on the testimonies of credible witnesses who positively identified Adriano as one of the perpetrators of the crime. The court also found no proof that the prosecution witnesses, PO1 Garabiles and PO2 Santos, had improper motives to testify against Adriano. The RTC ordered Adriano to pay the heirs of Cabiedes P222,482 as actual damages, including funeral expenses, burial expenses, groceries used and served during the wake, and parts and service repair of the CRV.

Adriano appealed to the Court of Appeals, arguing that the RTC erred in not accepting his alibi defense and in giving credence to the testimonies of the prosecution witnesses, claiming that they had inconsistent and contradictory statements. The Court of Appeals affirmed the decision of the RTC and increased the civil indemnity and moral damages awarded to the heirs of Cabiedes and Bulanan.

ISSUES:

  1. Whether the elements of murder were established by the prosecution.

  2. Whether treachery is present in the case.

  3. Whether the death of Bulanan can be imputed to the accused.

  4. Whether the acts committed by the accused constitute separate and distinct crimes or a complex crime.

  5. Whether treachery may be appreciated in aberratio ictus.

  6. Whether the death of the victim was duly established.

  7. Whether the defense of alibi is credible.

  8. Whether the evidence presented by the defense is credible.

  9. What penalty should be imposed for the crime of murder.

  10. Whether the claimant has established the actual amount of loss suffered.

RULING:

  1. The elements of murder were established by the prosecution. The fact of death of the victims, the positive identification of the accused as one of the perpetrators, and the attendance of qualifying and generic aggravating circumstances were proven.

  2. Treachery is present in the case. The victims were defenseless at the time of the attack and the accused consciously and deliberately employed means to ensure the victim's execution without risk to the offender.

  3. The death of Bulanan can be imputed to the accused under the doctrine of aberratio ictus. Although it wasn't the accused's intention to kill Bulanan, her death was a natural and direct consequence of the accused's act of shooting Cabiedes.

  4. The acts committed by the accused constitute separate and distinct crimes, not a complex crime.

  5. Treachery may be appreciated in aberratio ictus.

  6. The death of the victim was duly established.

  7. The defense of alibi is not credible.

  8. The evidence presented by the defense is not credible.

  9. The penalty of reclusion perpetua is imposed for the crime of murder.

  10. The claimant has established the actual amount of loss suffered.

PRINCIPLES:

  • In cases of murder, the presence of the elements of killing, the accused as the perpetrator, the attendance of qualifying circumstances, and the exclusion of parricide or infanticide must be established by the prosecution.

  • Treachery is defined as the direct employment of means that ensure the execution of the crime without risk to the offender arising from the defense that the victim might make. It requires the victim to be defenseless at the time of the attack and the accused to consciously and deliberately adopt the particular means of attack.

  • The doctrine of aberratio ictus imposes criminal liability for acts committed in violation of law and for all the natural and logical consequences resulting therefrom, regardless of the intention of the accused. The original intent is of no moment when a person other than the intended victim is killed.

  • When various victims expire from separate shots, such acts constitute separate and distinct crimes, not a complex crime.

  • Treachery may be appreciated in aberratio ictus.

  • Alibis, like denials, are inherently weak and unreliable because they can easily be fabricated.

  • Denial and alibi will not prevail when corroborated not by credible witnesses but by the accused's relatives and friends.

  • The penalty for murder under the Revised Penal Code is reclusion perpetua to death.

  • The claimant must establish with a reasonable degree of certainty, the actual amount of loss by means of competent proof or the best evidence obtainable.