Case Digest (G.R. No. 153591)
Facts:
People of the Philippines v. Renato Garcia y Romano, G.R. No. 153591, February 23, 2004, Supreme Court First Division, Ynarez‑Santiago, J., writing for the Court.Appellant Renato Garcia y Romano was charged by Information before the Regional Trial Court (RTC) of Quezon City, Branch 87, in Criminal Case No. Q-98-79961 with Murder allegedly committed on May 22, 1998, by driving a passenger jeepney in a careless, reckless and negligent manner and then willfully running the vehicle over the victim, Sanily Billon y Trinidad, qualified by evident premeditation and use of a motor vehicle.
At trial the prosecution narrated that at about noon on May 22, 1998, Sanily and her brother Bentley alighted from appellant’s jeepney on Zabarte Road near a school. Bentley waited at the center island while Sanily attempted to cross. A jeepney driven by appellant struck Sanily, who fell and was thrown to the ground; the vehicle stopped but then moved forward and its front tire ran over Sanily’s abdomen. Bentley and appellant pulled Sanily from under the vehicle, took her to Sta. Lucia Hospital, and later to Quezon City General Hospital (QCGH), where she underwent surgery and died four days later. Medico‑legal testimony (Dr. Emmanuel Reyes, testifying on Dr. Santiago Sagad’s clinical record) described lacerations to the liver and spleen and death from internal bleeding.
Appellant admitted that his vehicle ran over the victim but claimed the event was accidental: he said he heard a thud, immediately applied his brakes, alighted and found the girl under the vehicle; he and Bentley brought her to the hospital and he later learned of her death. At arraignment he pleaded not guilty and the case proceeded to trial.
On May 2, 2002, the RTC (Judge Fatima Gonzales Asdala) convicted appellant of Murder qualified by evident premeditation and sentenced him to reclusion perpetua, ordered indemnities (actual, civil and moral damages), and awarded costs. The RTC found that appellant deliberately ran over t...(Pro-only)
Issues:
- Did the trial court err in appreciating the qualifying circumstance of evident premeditation?
- Was appellant guilty beyond reasonable doubt of Murder, or did the facts instead establish reckless imprudence resulting...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)