In Philippine jurisprudence, the presence of treachery (alevosia) significantly elevates criminal liability, transforming what might be homicide into murder. The Supreme Court case of People v. Oandasan, Jr. clarifies how treachery is applied in scenarios involving multiple victims in quick succession. The Court ruled that when an attack is initiated with treachery against one victim, that treachery can extend to subsequent victims if the attacks occur as part of the same continuous act, ensuring that the accused is appropriately charged and convicted of murder rather than the lesser crime of homicide. This case underscores the importance of examining the totality of circumstances in determining the presence of aggravating circumstances.

One Assailant, Multiple Victims: Can Treachery Apply Across a Series of Rapid Attacks?

The narrative of People v. Oandasan, Jr. unfolds with Mariano Oandasan, Jr. being accused of fatally shooting Edgardo Tamanu and Danilo Montegrico, and inflicting near-fatal injuries on Mario Paleg during a drinking spree. The initial judgment by the trial court found Oandasan guilty of murder for Montegrico’s death, acknowledging the presence of treachery. However, it downgraded the charges for Tamanu’s death to homicide and for Paleg’s injuries to frustrated homicide, reasoning that treachery was not independently proven for these victims. The Court of Appeals affirmed this decision, prompting the appeal to the Supreme Court, which sought to re-evaluate the application of treachery across all three incidents.

At the heart of this legal challenge was whether treachery, once established in the initial attack, could be considered an aggravating circumstance for the subsequent attacks when they occurred in rapid succession. The Supreme Court addressed this by examining the factual circumstances surrounding the shootings. The prosecution presented evidence indicating that Oandasan had appeared suddenly and without warning, firing upon Montegrico and then continuing his assault on Tamanu and Paleg in quick succession. This sequence of events led the Supreme Court to conclude that treachery was indeed present in all three attacks. According to the Court, the unexpected nature of the initial assault, coupled with the swiftness of the subsequent attacks, prevented any of the victims from defending themselves, thus fulfilling the elements of treachery.

The Supreme Court emphasized that the essence of treachery lies in the sudden and unexpected nature of the attack, which deprives the victims of any opportunity to defend themselves or retaliate. The Court quoted Luces v. People, clarifying the conditions for treachery:

(a) that the means, methods and forms of execution employed gave the person attacked no opportunity to defend themselves or to retaliate; and (b) that such means, methods and forms of execution were deliberately and consciously adopted by the accused without danger to his person.

Building on this principle, the Court found that Oandasan’s actions met these criteria, as the attacks were swift, unexpected, and left the victims defenseless. The Court also referenced previous cases, such as People v. Flora and People v. Pinto, Jr., to support its position that treachery can extend to multiple victims in a single, continuous act of violence, especially when the victims are unable to defend themselves due to the suddenness and nature of the attack.

Furthermore, the Supreme Court addressed the argument that the lack of direct eyewitness testimony for the shootings of Tamanu and Paleg should preclude a finding of treachery. The Court clarified that circumstantial evidence is sufficient to establish guilt, provided that the circumstances are consistent with each other, consistent with the hypothesis that the accused is guilty, and inconsistent with any other rational hypothesis except that of guilt. The Court cited People v. Modesto, emphasizing that no general rule dictates the quantity of circumstantial evidence needed, but rather, the totality of circumstances must lead to a conviction beyond reasonable doubt.

In this context, the Court found that the circumstantial evidence overwhelmingly pointed to Oandasan as the perpetrator of all three attacks. The fact that the shootings occurred in rapid succession, coupled with the testimony identifying Oandasan as the initial assailant, sufficiently established his guilt beyond a reasonable doubt. Moreover, the Court dismissed Oandasan’s defense of alibi, noting that it could not outweigh the positive identification made by the prosecution’s witnesses. It reiterated that denial and alibi are weak defenses, especially when contradicted by credible eyewitness testimony or strong circumstantial evidence.

As a result of its findings, the Supreme Court modified the lower courts’ decisions, convicting Oandasan of two counts of murder for the deaths of Montegrico and Tamanu, and one count of frustrated murder for the injuries inflicted on Paleg. The Court also adjusted the civil liabilities, imposing appropriate damages for each crime, including civil indemnity, moral damages, exemplary damages, and temperate damages. These damages were assessed in accordance with prevailing jurisprudence and the principles of compensating victims of violent crimes.

Moreover, the Supreme Court revisited the issue of civil indemnity, tracing its historical progression from a minimum of P2,000 to the current standard, as outlined in People v. Jugueta. The Court acknowledged the need to adjust civil liabilities to reflect contemporary economic realities and ensure that victims and their families are adequately compensated for their losses. In line with this, it awarded P75,000 for civil indemnity, moral damages, and exemplary damages for each count of murder, and P50,000 for civil indemnity, moral damages, and exemplary damages for the frustrated murder, along with P50,000 as temperate damages to the heirs of Montegrico and Tamanu, and P25,000 to Paleg for his hospitalization expenses.

FAQs

What was the key issue in this case?	The key issue was whether treachery, established in an initial attack, could extend to subsequent attacks on multiple victims in a rapid sequence of events. The Supreme Court clarified the application of treachery in scenarios involving multiple victims during a single incident.
What is treachery (alevosia) in Philippine law?	Treachery is a circumstance where the offender employs means, methods, or forms in the execution of a crime that ensure its commission without risk to themselves arising from the defense the victim might make. It is an aggravating circumstance that qualifies killing to murder.
What evidence did the prosecution present to prove treachery?	The prosecution presented eyewitness testimony and circumstantial evidence showing that the accused launched a sudden and unexpected attack on the victims, giving them no opportunity to defend themselves. This suddenness and lack of warning constituted treachery.
Why were the initial charges for Tamanu and Paleg reduced to homicide and frustrated homicide?	The trial court initially ruled that treachery was not independently proven for the attacks on Tamanu and Paleg, leading to the downgrading of charges. This was based on the notion that treachery must be separately established for each victim.
How did the Supreme Court’s ruling change the initial convictions?	The Supreme Court modified the lower courts’ decisions by finding the accused guilty of two counts of murder and one count of frustrated murder, recognizing that treachery applied to all victims due to the continuous nature of the attack.
What is the significance of circumstantial evidence in this case?	The Supreme Court emphasized that circumstantial evidence can be sufficient to establish guilt beyond a reasonable doubt, especially when direct eyewitness testimony is lacking. The circumstances must be consistent with each other and lead to the conclusion that the accused is guilty.
What civil liabilities were imposed on the accused?	The accused was ordered to pay civil indemnity, moral damages, exemplary damages, and temperate damages to the heirs of the deceased victims and to the surviving victim, Paleg. These damages were intended to compensate for the losses and suffering caused by the crimes.
How did the Supreme Court address the issue of civil indemnity?	The Court revisited the historical progression of civil indemnity amounts, emphasizing the need to adjust them to reflect contemporary economic realities and ensure adequate compensation for victims. It ultimately awarded P75,000 for civil indemnity in each murder case.

The People v. Oandasan, Jr. case serves as a crucial reminder of the legal principles surrounding treachery and its application in criminal cases involving multiple victims. By clarifying the conditions under which treachery can extend to subsequent attacks, the Supreme Court ensured that the accused was held accountable for the full extent of his crimes. This case also highlights the importance of circumstantial evidence and the need to adjust civil liabilities to reflect contemporary economic conditions, thereby providing just compensation to victims and their families.

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 v. Oandasan, Jr., G.R. No. 194605, June 14, 2016