Case Digest (G.R. No. 84332-33)
Facts:
On January 2, 1985 in Caloocan City, the victim Efren Arceo was fatally shot while asleep; his wife Priscilla identified her former neighbor Reynaldo Evangelista as the fleeing assailant, ballistics linked the fatal bullet to a homemade paltik recovered after a purported confession to Patrolman Carlos Ladia, and the People of the Philippines charged Evangelista with murder (RTC Criminal Case No. C-23861) and violation of P.D. No. 1866 (Criminal Case No. C-23862). The Regional Trial Court convicted him of murder and aggravated illegal possession of firearm, sentencing him to reclusion perpetua and death respectively; the case reached the Court on automatic review.
Issues:
- Did the evidence prove beyond reasonable doubt that Reynaldo Evangelista committed murder?
- Did the killing exhibit treachery to qualify as murder?
- Was the alleged extrajudicial confession inadmissible for lack of the Miranda warning?
- Can Evangelista be convicted of aggravated illegal possession of firearm under P.D. No. 1866 absent specific allegations and proof that the firearm was unlicensed and used in the homicide?
Ruling:
The Court affirmed the conviction for murder, upheld the finding of treachery, and held the extrajudicial confession admissible; it increased civil indemnity to P50,000.00 and, by operation of the 1987 Constitution, reduced the death sentence to reclusion perpetua. The Court reversed the conviction for illegal possession of firearm and acquitted Evangelista of that charge.
Ratio:
The Court found the prosecution established identity by positive eyewitness identification at a distance of about four meters with street illumination, motive from a prior altercation, ballistic proof that the fatal bullet was fired from the recovered paltik, and a voluntary confession made before arrest such that the Miranda warning was not required because Evangelista was not yet in custodial interrogation; the alibi was rejected as weak and physically possible to disprove. Treachery was present because the victim was killed while asleep. The firearm charge failed for want of an allegation and proof that the paltik was unlicensed and that it was used in the murder; a paltik is not ipso facto unlicensable and the aggravated form must be pleaded to support enhanced punishment.
Doctrine:
- Identification by a witness who knew the accused and observed him under sufficient lighting at close range may sustain a conviction.
- Motive, while generally irrelevant, is material when coupled with other evidence to establish identity.
- The Miranda warning is required only when custodial interrogation occurs; a voluntary admission made before arrest is admissible.
- Killing a person while asleep constitutes treachery.
- Conviction for aggravated illegal possession of firearm requires that the information allege the firearm was unlicensed and used to commit the principal crime.
- A homemade firearm (paltik) is not conclusively unlicensable; proof that it is unlicensed is necessary for conviction.
- Sentences of death imposed before the effectivity of the 1987 Constitution were reduced in accordance with its prohibition on the death penalty.