People vs. Flores

G.R. No. 116524 (January 18, 1996)

Lyndon Flores' murder conviction upheld; penalty modified to indeterminate sentence due to treachery.

Facts:

On June 20, 1993, at around noon, in Barangay Malusak, Boac, Marinduque, Lyndon Flores y Malarayap (the accused) was involved in an altercation with Manuel Lazarte y Malvar (the victim), who was lying unconscious on the pavement due to intoxication. Witnesses, including Cesar Lanot and Alfredo Alvarez, testified that the accused kicked the victim multiple times in the stomach and chest while he was incapacitated. The altercation stemmed from a dispute over a cassette recorder that the victim's mother, Emperatriz Lazarte, believed the accused had stolen.

After the incident, the victim was taken to the hospital, where he was diagnosed with a ruptured small intestine, which ultimately led to his death two days later. Medical testimony indicated that the injuries were consistent with severe kicks to the abdomen. The accused denied kicking the victim, claiming he only nudged him to wake him up so that the victim could explain the circumstances surrounding the missing cassette recorder.

Legal Issues:

  1. Whether the accused committed murder or simple homicide.
  2. Whether the trial court erred in imposing the penalty of reclusion perpetua instead of a lesser penalty.

Arguments:

  • Prosecution's Argument: The prosecution argued that the accused's actions constituted murder due to the treachery involved in attacking an unconscious victim. The evidence presented, including eyewitness testimonies, established that the accused deliberately kicked the victim multiple times, leading to fatal injuries. The prosecution sought the imposition of the maximum penalty for murder.

  • Defense's Argument: The defense contended that the accused did not intend to kill the victim and that his actions were merely an attempt to wake him up. The defense argued that the crime should be classified as simple homicide rather than murder, asserting that the accused lacked the intent to commit such a grave offense.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision to convict the accused of murder, finding that the evidence clearly established the elements of the crime, including the presence of treachery. The court noted that the victim was completely defenseless at the time of the attack, which qualified the act as treacherous.

However, the court found merit in the defense's argument regarding the penalty. It recognized the mitigating circumstance of lack of intent to commit so grave a wrong, as the accused did not intend to kill the victim but rather to inflict injuries. Consequently, the court modified the penalty from reclusion perpetua to an indeterminate prison term of ten years and one day of prision mayor as the minimum, to seventeen years and four months and one day of reclusion temporal as the maximum.

Significant Legal Principles Established:

  1. Treachery as a Qualifying Circumstance: The court reiterated that treachery exists when the offender employs means that ensure the execution of the crime without risk to himself from any defense the victim might make.

  2. Mitigating Circumstances: The court acknowledged that lack of intent to commit a grave wrong can be a mitigating circumstance, affecting the penalty imposed.

  3. Indeterminate Sentence Law: The decision highlighted the application of the Indeterminate Sentence Law, which allows for a range of penalties based on the presence of mitigating and aggravating circumstances.