G.R. No. L-48744 - People vs. Centeno

Case Summary (G.R. No. L-48744)

Parties, Charging Allegation, and Trial-Level Conviction

At the trial court level, the accused were charged with murder. The Court of First Instance found them guilty of simple homicide, and also found against the accused the alleged qualifying circumstances of treachery and evident premeditation in the sense that those qualifying allegations were “not having been found to be present.” As a result, the trial court sentenced each accused to an indeterminate penalty: imprisonment of not less than SIX (6) YEARS, EIGHT (8) MONTHS and ONE (1) DAY of prision mayor as minimum, to not more than FIFTEEN (15) YEARS, SIX (6) MONTHS and TWENTY-ONE (21) DAYS of reclusion temporal as maximum.

The trial court also imposed accessory penalties provided by law and ordered the accused to indemnify the heirs of the deceased in the amounts of P12,000.00 for the death of Nestor Asistido, P33,696.00 for loss of income, and P10,000.00 for moral damages, plus costs. The court appreciated in favor of the accused the mitigating circumstance of voluntary surrender.

Appellate Posture in the Court of Appeals

On appeal, the Court of Appeals did not affirm or modify the trial court judgment. It stated that it adopted the view of the Solicitor General that the crime committed was murder, for which the Solicitor General recommended the penalty of death, because it believed treachery was present and that evident premeditation aggravated the offense. The Court of Appeals nevertheless expressed that the proper penalty could be life imprisonment or death, but it refrained from imposing either.

Instead of entering judgment, the Court of Appeals certified the case to the Supreme Court for final determination, allegedly pursuant to Section 34 of the Judiciary Act and Section 12 of Rule 124 of the Rules of Court. This procedural route prompted review on the question of what appellate action the Court of Appeals should take when it believes that the proper imposable penalty is death or reclusion perpetua, even though the trial court had imposed a lesser penalty.

The Controlling Procedural Doctrine: People vs. Daniel

The Supreme Court noted that it had “recently held” in a similar situation that the Court of Appeals should render judgment expressly and explicitly imposing either death or reclusion perpetua as the circumstances warrant, rather than merely certifying the case. The Supreme Court relied specifically on People vs. Daniel, G.R. No. L-40330 (November 20, 1978), where the Court directed that henceforth, when the Court of Appeals is of the opinion that either the penalty of death or reclusion perpetua should be imposed in any criminal case appealed to it and the penalty imposed by the trial court is less than reclusion perpetua, the Court of Appeals must, with a comprehensive written analysis of the evidence and a discussion of the law involved, render judgment expressly and explicitly imposing the appropriate penalty. The Court in Daniel instructed the Court of Appeals to “refrain from entering judgment” in the context of the earlier certification practice, but the clear thrust of the directive was to require an express imposition by the Court of Appeals before elevation for review.

The Supreme Court further cited People vs. Lucas Ramos, G.R. No. L-49818 (February 20, 1979) as applying the Daniel directive in returning the case for the imposition of the proper penalty.

Supreme Court Disposition in the Present Case

In the present case, the Supreme Court directed that the matter should be returned to the Court of Appeals for the imposition of the proper penalty. It did so by characterizing the Court of Appeals’ certification without entry of an express penalty as inconsistent with the operative Daniel doctrine. The Supreme Court therefore refrained from reassessing the sufficiency of the Court of Appeals’ assessment of the evidence as to the correct penalty, because the case had to be handled in accordance with the controlling procedural command.

Legal Basis and Reasoning: Adherence to the Daniel Doctrine

The resolution framed the issue as one of appellate procedure and jurisdictional allocation in criminal cases. The Court acknowledged a discussion, in the opinion of Justice De Castro, regarding the earlier practice and the constitutional and statutory framing of appellate jurisdiction over cases where the penalty is death or life imprisonment. The narrative in the resolution reflected competing views on whether requiring the Court of Appeals to render a decision expressly imposing death or reclusion perpetua was consistent with prior practice, and whether the statutory and constitutional structure would make certain interpretations constitutionally objectionable.

However, regardless of those personal views, the Supreme Court declared that the “controlling effect” of People vs. Daniel “has to be conceded.” It then applied the Daniel doctrine as binding, directing that the Court of Appeals determine for itself the proper penalty under its own analysis of the evidence, but in accordance with the ruling that required the Court of Appeals’ judgment to expressly and explicitly impose the proper penalty.

The Supreme Court thus treated the Daniel doctrine not as a suggestion but as a procedural rule to be followed, and it left any reconsideration of its correctness to future appropriate cases.

Separate Opinion and Concurrence in the Result

Teehankee, J. filed a separate opinion. He stated that he held the opposite view from the main opinion’s implied direction, aligning with Justice De Castro’s personal view that, under the long-standing interpretation, when the Court of Appeals believes that death or life imprisonment should be imposed in an appealed criminal case where the trial court imposed a lesser penalty, it should refrain from rendering judgment and should forthwith certify the case to the Supreme Court for final determination as if it had been brought before the Supreme Court on appeal. He explained that, in his view, the Court by a bare majority had overruled that long-standing doctrine in Daniel, which compelled a protracted process of returning cases to the Court of Appeals for express imposition of either death or reclusion perpetua, even while the Court of Appeals is directed to refrain from entering judgment and to certify agai

Case Syllabus (G.R. No. L-48744)

Parties and Procedural Posture

The People of the Philippines prosecuted Francisco Centeno, Juan Centeno alias Totok, and Manuel Centeno alias Iyao for Murder before the Court of First Instance of Iloilo.
The trial court found the accused guilty of simple homicide and appreciated treachery and evident premeditation only as alleged qualifying circumstances not having been found to be present.
The trial court imposed a composite set of penalties and damages, and it appreciated in the accused’ favor the mitigating circumstance of voluntary surrender.
On appeal, the Court of Appeals neither affirmed nor modified the conviction.
The Court of Appeals treated the case as requiring either life imprisonment or death, because it adopted the Solicitor General’s view that the crime is Murder due to treachery aggravated by evident premeditation, but it refrained from imposing a final penalty.
The Court of Appeals certified the case to the Supreme Court for final determination, claiming it acted in pursuance of Section 34 of the Judiciary Act and Section 12 of Rule 124 of the Rules of Court.
The ponente referred to the Court’s ruling in People vs. Daniel (G.R. No. L-40330, November 20, 1978) and to People vs. Lucas Ramos (G.R. No. L-49818, February 20, 1979), which required the Court of Appeals to render explicit judgment on death or reclusion perpetua upon appellate review.
The decision also contained a judicial discussion of the conflict between Daniel and prior practice, followed by a directive to return the record to the Court of Appeals for the proper action.

Key Factual Allegations

The accused were charged with Murder arising from the killing of Nestor Asistido.
The trial court determined that the qualifying circumstances of treachery and evident premeditation alleged in the information were not present for purposes of elevating the offense to murder.
The trial court’s findings thus supported a conviction only for simple homicide.
The judgment awarded civil indemnity and other damages to the heirs Arsenio Asistido and Nenita C. Asistido as the representatives of the deceased’s interest.

Trial Court Disposition

The Court of First Instance of Iloilo convicted Francisco Centeno, Juan Centeno alias Totok, and Manuel Centeno alias Iyao of simple homicide and denied the qualifying circumstances alleged in the information for elevating the offense to Murder.
The trial court imposed for each accused a minimum term of imprisonment of not less than SIX (6) YEARS, EIGHT (8) MONTHS and ONE (1) DAY of prision mayor and a maximum term of not more than FIFTEEN (15) YEARS, SIX (6) MONTHS and TWENTY-ONE (21) DAYS of reclusion temporal.
The trial court imposed accessory penalties provided for by law.
The trial court ordered the accused to indemnify Arsenio Asistido and Nenita C. Asistido, heirs of the deceased, in the amount of P12,000.00 for the death of Nestor Asistido, and P33,696.00 for loss of income.
The trial court additionally awarded P10,000.00 for moral damages.
The trial court directed the accused to pay the costs.
The trial court appreciated voluntary surrender as a mitigating circumstance in favor of the accused.

Court of Appeals Certification

The Court of Appeals did not affirm or modify the trial court judgment.
The Court of Appeals stated that it adopted the Solicitor General’s view that the crime committed was Murder, and that treachery existed and was aggravated by evident premeditation.
The Court of Appeals reasoned that, because of the qualifying circumstances, the penalty could be life imprisonment or death.
The Court of Appeals declined to impose either penalty and instead certified the case to the Supreme Court for final determination.
The certification was justified by the Court of Appeals as being made pursuant to Section 34 of the Judiciary Act and Section 12 of Rule 124 of the Rules of Court.

Issues Framed for Review

The Supreme Court confronted the procedural question whether the Court of Appeals should render an express and explicit appellate judgment imposing death or reclusion perpetua when it finds that such penalty is proper, or whether it may continue the older practice of certifying the case without entering judgment.
The Court also considered whether the statutory command to the Court of Appeals to “refrain from rendering judgment” properly requires the Daniel procedure, including an explicit penalty decision, or whether certification suffices.
The analysis necessarily involved the interaction of Section 34 of the Judiciary Act and the constitutional appellate jurisdiction over criminal cases involving death or life imprisonment.
The decision implicated the continuing controlling effect of People vs. Daniel, despite concerns voiced by the ponente and by separate opinions about its practical implications and constitutional coherence.

Statutory and Constitutional Framework

The ponente discussed Section 17 of the Judiciary Act, emphasizing its allocation of exclusive Supreme Court review in criminal cases involving offenses where the penalty imposed is death or life imprisonment.
The ponente treated the view that Section 17 of the Judiciary Act could be read as an unauthorized enlargement of Supreme Court power as an argument raising potential constitutional infirmity.
The ponente alternatively treated the same statutory allocation as a permissible limitation on the Court of Appeals’ jurisdiction, as the