Case Digest (G.R. No. 75074)
Case Digest (G.R. No. 75074)
Facts:
People of the Philippines v. Oscar Ocaya, G.R. No. 75074, September 15, 1986, First Division, Melencio-Herrera, J., writing for the Court. The case concerns the killing of Mario Origines and the conviction on a charge of murder.On the night of March 7, 1982, at about 9:00–9:20 p.m., an assailant called at the house of Bonifacia Varquez in Barangay Lawa-an, Aloran, Misamis Occidental. When Mario Origines opened the door, a man wearing a raincoat with a hood stabbed him repeatedly with a long bolo. A scuffle ensued; during the struggle the hood was pulled down exposing the attacker’s face. Two occupants, Julita Bulaga and German Origines, Jr., who were acquainted with the accused, later identified the assailant in court as Oscar Ocaya. The victim died of stab wounds; Dr. Rogelio R. Roa performed the autopsy and certified the cause of death as shock due to profuse internal and external hemorrhage from stab wounds.
Police reports made shortly after the incident initially recorded the culprit as unknown, but three days later (March 10, 1982) the two eyewitnesses executed sworn statements naming Ocaya; the complaint followed. At trial before the Regional Trial Court, Branch XII, Oroquieta City, Ocaya contested identification and asserted an alibi. The trial court nevertheless convicted him and sentenced him "to suffer an indeterminate penalty of from fourteen (14) years, eight (8) months and one (1) day, as minimum, to seventeen (17) years and four (4) months of reclusion temporal, as maximum; to indemnify the heirs ... P30,000.00; to pay P3,000.00 ...; to suffer the accessory penalties ... and to pay the costs."
On June 10, 1986, the Court of Appeals (Second Criminal Cases Division) affirmed the conviction but modified the penalty, concluding that murder under Article 248, Revised Penal Code warranted reclusion perpetua in its medium period where there were no aggravating or mitigating circumstances; the division held that the indeterminate sentence law was inapplicable (citing People v. Cuevas, 97 Phil. 963) and, because the modified penalty involved life imprisonment, certified the case to the Supreme Court pursuant to Section 2, Article I of the Provisional Constitution (Proclamation No. 3) adopting Article X (The Judiciary) of the 1973 Constitution and Section 12, Rule 124, Rules of Court. The case was certified to the Supreme Court and, in a Resolution dated July 14, 1986, the Court accepted and docketed it for final determination.
Issues:
- Was certification of the case to the Supreme Court proper under Section 2, Article I of the Provisional Constitution and Section 12, Rule 124, Rules of Court?
- Was accused proven guilty beyond reasonable doubt of murder based on the eyewitness identifications and other evidence?
- Did the initial police report (stating the culprit was unknown) and the accused’s alibi sufficiently undermine the identifications to require acquittal or reversal?
- Was the indeterminate sentence applicable, or should reclusion perpetua be imposed for murder under Article 248, Revised Penal Code?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)