Case Digest (G.R. No. L-48744)
Facts:
The People of the Philippines v. Francisco Centeno, Juan Centeno alias Totok, Manuel Centeno alias Iyao, G.R. No. L-48744, October 30, 1981, the Supreme Court Second Division, De Castro, J., writing for the Court.The prosecution (plaintiff-appellee) charged Francisco Centeno, Juan Centeno alias Totok, and Manuel Centeno alias Iyao (accused-appellants) with murder in the Court of First Instance of Iloilo. The trial court, however, found that the qualifying circumstances of treachery and evident premeditation were not established and convicted the accused of simple homicide, imposing prison terms ranging from prision mayor as minimum to reclusion temporal as maximum, plus civil indemnities, moral damages and costs, and crediting the mitigating circumstance of voluntary surrender.
On appeal, the Court of Appeals did not simply affirm or modify the trial court’s judgment. Adopting the Solicitor General’s view that the facts established the crime of murder with qualifying circumstances of treachery and aggravation by evident premeditation, the Court of Appeals concluded that the proper penalty could be either death or reclusion perpetua (life imprisonment). Instead of selecting and entering one of those penalties, the Court of Appeals refrained from imposing a sentence and certified the case to the Supreme Court for final determination, invoking Section 34 of the Judiciary Act and Section 12 of Rule 124 of the Rules of Court.
The Supreme Court, invoking its prior ruling in People v. Daniel (G.R. No. L-40330, November 20, 1978) and related authority, concluded that the present case should be returned to the Court of Appeals to permit that court to impose the proper penalty in accordance with the Daniel doctrine. The Court expressly refrained from re-evaluating the Court of Appeals’ assessment of the evidence and directed the remand for action consistent with existing controlling precedent. Several justices concurred; Justice Teehankee filed a separate opinion concurring in the result but reiterating opposition to the Daniel doctrine.
This case r...(Pro-only)
Issues:
- Was the Court of Appeals required to refrain from entering judgment and instead certify the case to the Supreme Court where it believed the proper penalty to be death or reclusion perpetua, under Section 34 of the Judiciary Act and Section 12 of Rule 124 (the Daniel doctrine)?
- Should the Supreme Court itself determine and impose the proper penalty on the record, or remit the matter to the Court of Appeals for imposition...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)