Case Summary (G.R. No. L-34940)
Factual Background
The Court of First Instance of Manila convicted Lacanilao of homicide related to the death of Erese, imposing an indeterminate penalty of six years and one day of prision mayor as the minimum, and fourteen years, eight months, and one day of reclusion temporal as the maximum. An indemnity of P20,000.00 was also mandated for Erese's heirs, along with the adjudication of costs. Following this conviction, Lacanilao appealed to the Court of Appeals, which modified his sentence, reducing the maximum penalty to twelve years and one day of reclusion temporal while affirming all other aspects of the lower court’s ruling.
Legal Issue
The principal legal question presented in this appeal focuses on the applicability of Article 69 of the Revised Penal Code. This article pertains to penalties applicable when the crime is not wholly justifiable, querying whether the incomplete fulfillment of duty or lawful exercise of right applies to Lacanilao's circumstances and if this should result in a degree reduction of the penalty.
Court of Appeals Findings
In its ruling, the Court of Appeals acknowledged that Lacanilao acted in the performance of his duty when he attempted to stop Erese’s disorderly conduct. However, the court concluded that Erese's shooting was not a necessary consequence of this duty, resulting in a finding of incomplete fulfillment of duty as a mitigating circumstance. They thus applied a modification of the penalty in accordance with this conclusion, reducing the term from the original sentence.
Supreme Court Ruling
The Supreme Court found merit in Lacanilao's petition, determining that the Court of Appeals erred in its application of mitigating circumstances. It asserted that incomplete justification is a special mitigating circumstance, which warrants a reduction of the penalty by one or two degrees, as provided in Article 69 of the Revised Penal Code. The Supreme Court maintained that Article 69 specifically accommodates scenarios wherein essential components of justification are absent, which was the case for Lacanilao since only one of the two requisite conditions laid out in Article 11, paragraph 5, was satisfied.
Interpretation of Mitigating Circumstances
The Supreme Court underscored that the law should be interpreted liberally in favor of the accused, particularly regarding provisions that mitigate penalties. It reiterated that Article 69 i
...continue readingCase Syllabus (G.R. No. L-34940)
Case Background
- The case involves petitioner Bernardo Lacanilao, a policeman found guilty of homicide for the shooting death of Ceferino Erese.
- The Court of First Instance of Manila sentenced Lacanilao to an indeterminate penalty of six years and one day of prision mayor as the minimum, and fourteen years, eight months, and one day of reclusion temporal as the maximum, along with a P20,000 indemnity to the victim's heirs.
- Lacanilao appealed the decision, leading to a review by the Court of Appeals.
Court of Appeals Decision
- The Court of Appeals modified the penalty, reducing it to an indeterminate penalty of six years and one day of prision mayor as the minimum and twelve years and one day of reclusion temporal as the maximum.
- The appellate court affirmed other aspects of the lower court's decision, including the indemnity and costs against the appellant.
- The court acknowledged that while Lacanilao acted in the performance of his duty, the shooting was not the necessary consequence of such duty.
Legal Issues Presented
- The primary legal question addressed was whether Article 69 of the Revised Penal Code should apply to the factual circumstances of the case, which would allow for the penalty to be