In People of the Philippines v. Romeo Llanda, the Supreme Court affirmed the conviction of Romeo Llanda for murder, despite his fugitive status. This case underscores the principle that an accused person’s flight from justice does not prevent the Court from reviewing cases involving the death penalty, which it is bound to do. The decision emphasizes the importance of witness credibility and the prosecution’s burden to prove guilt beyond a reasonable doubt, even when the accused is not present to defend themselves. This ruling reinforces the idea that justice must be served, and that the Court will uphold its duty to review death penalty cases, regardless of the accused’s attempts to evade the law.

Fugitive’s Flight: Can Justice Prevail in Absentia?

The case revolves around the murder of Cornelio Coronado on September 3, 1994, in Misamis Occidental. Romeo Llanda was charged with fatally shooting Coronado. However, Llanda escaped before his trial could commence, leading the court to proceed in absentia. The prosecution presented testimonies from the victim’s family members, who identified Llanda as the shooter. The defense countered with alibi and denial, claiming that the victim’s son was the actual perpetrator. The trial court, finding the prosecution’s evidence more credible, convicted Llanda of murder and sentenced him to death.

The Supreme Court was tasked with automatically reviewing the case due to the imposition of the death penalty. Even though Llanda remained at large, the Court proceeded, emphasizing its constitutional duty to review all death penalty cases. The core issues were the sufficiency of the prosecution’s evidence and the propriety of the death sentence. Llanda argued that the trial court erred in appreciating treachery and dwelling as aggravating circumstances, and in finding him guilty of murder beyond a reasonable doubt. The prosecution, however, maintained that the evidence overwhelmingly pointed to Llanda as the perpetrator, with the testimonies of the victim’s family members corroborating each other.

The Court scrutinized the testimonies of the prosecution witnesses, particularly the victim’s family, and found them credible and consistent. It reiterated the established rule that appellate courts generally defer to the trial court’s assessment of witness credibility, unless there is a clear showing that the trial court overlooked significant facts. The Court found no reason to doubt the testimonies of the prosecution witnesses, as Llanda failed to show any improper motive on their part. In contrast, the Court found the testimony of the defense witness, Juan Otom, highly incredible. Otom’s claim that the victim’s son was the actual killer was deemed biased and lacking in conviction.

The Court also addressed Llanda’s defense of alibi, which it deemed weak and unreliable. To successfully invoke alibi, an accused must prove that it was physically impossible for them to be at the crime scene at the time of the incident. Llanda failed to demonstrate this impossibility. Furthermore, the Court noted that Llanda’s flight before his trial was a strong indication of guilt. The Court stated,

“Flight of an accused, when unexplained, is a circumstance from which an inference of guilt might be drawn, for a truly innocent person would normally grasp the first available opportunity to defend himself and to assert his innocence of the crime imputed to him.”

Having established that Llanda was indeed the perpetrator, the Court turned to the issue of whether the attendant circumstances of treachery and dwelling were properly appreciated. The Court found that treachery was present, as the victim was shot suddenly and unexpectedly, leaving him no opportunity to defend himself. The elements of treachery are: (1) the employment of means of execution that give the person attacked no opportunity to defend himself or to retaliate; and (2) the means of execution were deliberately or consciously adopted. Here, the sudden shooting satisfied both elements.

However, the Court disagreed with the trial court’s finding that dwelling aggravated the offense. The information against Llanda did not allege dwelling as an aggravating circumstance. Citing Sections 8 and 9, Rule 110 of the Revised Rules of Criminal Procedure, the Court emphasized that the information must specify all qualifying and aggravating circumstances. Since dwelling was not alleged, it could not be considered as an aggravating circumstance. The current rules state:

SEC. 8. Designation of the offense. – The complaint or information shall state the designation of the offense given by the statute, aver the acts or omissions constituting the offense, and specify its qualifying and aggravating circumstances. If there is no designation of the offense, reference shall be made to the section or subsection of the statute punishing it.

Therefore, while the killing was qualified by treachery, the absence of any other aggravating circumstance meant that the penalty should be reduced from death to reclusion perpetua, since under Article 248 of the Revised Penal Code, the penalty for murder is reclusion perpetua to death. In imposing the penalty, the court followed Article 63 of the Revised Penal Code.

ART. 63. Rules for the application of indivisible penalties. – In all cases in which the law prescribes a single indivisible penalty, it shall be applied by the courts regardless of any mitigating or aggravating circumstances that may have attended the commission of the deed.

The Court also addressed the issue of damages, upholding the award of civil indemnity of P50,000 but adding an additional P50,000 as moral damages, in line with current jurisprudence. This addition aims to provide further compensation to the victim’s heirs for the emotional suffering caused by the crime. The award of civil indemnity is standard in murder cases, while moral damages are intended to alleviate the mental anguish experienced by the victim’s family.

The defense’s argument that the victim’s family should have taken precautions due to a prior altercation between the victim and Llanda’s father was dismissed. The Court emphasized that the sudden and unexpected nature of the attack constituted treachery, regardless of any prior disputes. This finding underscores the importance of protecting individuals from unforeseen violence, even in situations where there may be existing tensions or conflicts.

Ultimately, the Supreme Court’s decision affirms the conviction of Romeo Llanda for murder, but modifies the sentence from death to reclusion perpetua. The Court’s adherence to procedural rules, particularly regarding the allegation of aggravating circumstances, demonstrates its commitment to ensuring fairness and due process, even in cases involving heinous crimes. The ruling serves as a reminder that justice will be served, regardless of an accused person’s attempts to evade the law, and that the Court will uphold its duty to review death penalty cases to ensure their legality and propriety.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution presented sufficient evidence to convict Romeo Llanda of murder beyond a reasonable doubt, despite his absence due to being a fugitive. The Court also examined if the aggravating circumstances of treachery and dwelling were properly appreciated.
Why did the Supreme Court review the case even though the accused was a fugitive?	The Supreme Court is constitutionally mandated to review all cases where the death penalty is imposed. This duty remains regardless of the accused’s fugitive status to ensure the sentence’s legality and propriety.
What is the significance of “treachery” in this case?	Treachery is a qualifying circumstance that elevates a killing to murder. It means the offender employed means to ensure the execution of the crime without risk to themselves, leaving the victim unable to defend themselves.
Why was “dwelling” not considered an aggravating circumstance?	“Dwelling” was not considered because it was not explicitly alleged in the information filed against the accused. The Revised Rules of Criminal Procedure require that all qualifying and aggravating circumstances be stated in the information.
What is the difference between civil indemnity and moral damages?	Civil indemnity is awarded as compensation for the death of the victim. Moral damages are awarded to the victim’s heirs to compensate for the emotional suffering and mental anguish caused by the crime.
What role did witness credibility play in the Court’s decision?	Witness credibility was crucial. The Court gave significant weight to the consistent and credible testimonies of the victim’s family members, who positively identified the accused as the shooter.
How did the accused’s flight affect the Court’s assessment of the case?	The accused’s flight was considered a strong indication of guilt. The Court reasoned that an innocent person would typically remain to defend themselves and assert their innocence.
What was the final ruling of the Supreme Court?	The Supreme Court affirmed the conviction of Romeo Llanda for murder but modified the sentence from death to reclusion perpetua. The Court also ordered Llanda to pay the victim’s heirs P50,000 as civil indemnity and P50,000 as moral damages.

This case serves as a legal precedent, highlighting the judiciary’s resolve to ensure that justice prevails, even when the accused is at large. It underscores the significance of proper legal procedures, especially regarding aggravating circumstances, and ensures that penalties are justly applied based on established facts and legal principles.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People of the Philippines, Plaintiff-Appellee, vs. Romeo Llanda, Accused-Appellant., G.R. No. 133386, November 27, 2002