In People v. Fieldad, the Supreme Court affirmed the conviction of inmates for the murder of jail guards, highlighting the legal concept of treachery even within the confines of a prison. This decision underscores that even armed individuals can be victims of treachery if they are rendered defenseless by a sudden and unexpected attack. The court also clarified the elements of carnapping and the defense of uncontrollable fear, setting a high bar for its successful invocation. Ultimately, the ruling reinforces the principle that those who conspire to commit heinous crimes will be held accountable, irrespective of their location or asserted justifications.

Behind Bars, Beyond Defense: Can Treachery Exist in a Jailhouse Murder?

The case revolves around the events of March 9, 1999, inside the Bureau of Jail Management and Penology (BJMP) Compound in Urdaneta City. Several inmates, including Charlie Fieldad, Ryan Cornista, and Edgar Pimentel, were accused of conspiring to murder two jail guards, JO2 Reynaldo Gamboa and JO1 Juan Bacolor, Jr., and subsequently carnapping a vehicle to aid their escape. The central legal question is whether the elements of murder, particularly treachery and conspiracy, can be established beyond reasonable doubt in a prison setting, and whether the defense of uncontrollable fear can excuse the crime of carnapping.

The prosecution presented evidence that the inmates, armed with an unlicensed firearm, attacked the jail guards in a coordinated manner. Julius Chan initiated the assault by shooting JO2 Gamboa, while Fieldad and Cornista grappled with JO1 Bacolor. Cornista struck JO1 Bacolor, causing him to fall, and Fieldad then used JO2 Gamboa’s gun to shoot JO1 Bacolor. Following the killings, the inmates escaped, taking a Tamaraw jeep without the owner’s consent. The trial court found Fieldad, Cornista, and Pimentel guilty of murder and carnapping. The Court of Appeals affirmed the decision with modifications, particularly regarding Cornista’s sentence due to his minority at the time of the crime. Only Fieldad and Pimentel pursued the appeal to the Supreme Court.

A critical aspect of the case is the element of treachery. According to the Revised Penal Code, there is treachery when the offender commits any of the crimes against the person, employing means, methods, or forms in the execution thereof which tend directly and specially to ensure its execution, without risk to himself arising from the defense which the offended party might take. Fieldad argued that treachery could not be present because the jail guards were armed and responsible for maintaining order, implying they were always prepared for potential threats. However, the Supreme Court rejected this argument, citing People v. Escote, Jr., which stated:

Treachery may also be appreciated even if the victim was warned of the danger to his life where he was defenseless and unable to flee at the time of the infliction of the coup de grace.

The court emphasized that despite being armed, the jail officers were given no chance to defend themselves against the sudden and coordinated attack. This aligns with the ruling in People v. Tabaco, where treachery was appreciated in the killing of peace officers who were taken by surprise and had no means of defending themselves.

Another key element is the identification of Fieldad as a participant in the killings. Fieldad argued that since JO2 Niturada did not specifically identify him, his involvement was not established. However, the prosecution presented the testimony of Dionisio Badua, an inmate who witnessed the events. Badua’s testimony directly implicated Fieldad in the assault on JO1 Bacolor and the subsequent shooting. The court gave significant weight to Badua’s testimony because the trial court had the opportunity to observe his demeanor and assess his credibility firsthand. It is a settled rule that the evaluation of the credibility of witnesses and their testimonies is a matter best undertaken by the trial court because of its unique opportunity to observe the witnesses firsthand and to note their demeanor, conduct and attitude under grilling examination.

The Court also considered circumstantial evidence to corroborate Badua’s testimony. This evidence included the fact that Fieldad was seen with the other inmates involved in the attack, and that a paraffin test on Fieldad’s hands came back positive for gunpowder nitrates. The defense attempted to challenge the validity of the paraffin test, arguing that it was conducted without the presence of counsel. However, the court noted that the taking of paraffin casts does not violate the right against self-incrimination. The Supreme Court had previously stated in People v. Gamboa:

His right against self incrimination is not violated by the taking of the paraffin test of his hands. This constitutional right extends only to testimonial compulsion and not when the body of the accused is proposed to be examined as in this case.

Furthermore, the court addressed the issue of conspiracy. A conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. Fieldad contended that his actions did not demonstrate an agreement with the other inmates to commit the crime. However, the court found that Fieldad’s actions before, during, and after the attacks showed a clear agreement and joint purpose. Conspiracy can be inferred from and established by the acts of the accused themselves when said acts point to a joint purpose and design, concerted action and community of interest.

Turning to the charge of carnapping, the elements of the crime are: (1) there is an actual taking of the vehicle; (2) the offender intends to gain from the taking of the vehicle; (3) the vehicle belongs to a person other than the offender himself; and (4) the taking is without the consent of the owner thereof, or it was committed by means of violence against or intimidation of persons, or by using force upon things. All the elements of carnapping are present in this case. Fieldad and Pimentel argued that they were forced to take the Tamaraw jeep by Leal, invoking the defense of uncontrollable fear. Under Article 12 of the Revised Penal Code, a person is exempt from criminal liability if he acts under the impulse of an uncontrollable fear of an equal or greater injury. However, the court found that this defense did not apply because Fieldad and Pimentel had ample opportunity to escape and did not act under such imminent threat.

The Supreme Court upheld the trial court’s decision on carnapping, noting that the intent to gain is presumed from the unlawful taking of the vehicle, as stated in People v. Bustinera:

Intent to gain or animus lucrandi is an internal act, presumed from the unlawful taking of the motor vehicle. Actual gain is irrelevant as the important consideration is the intent to gain.

The court also addressed the award of damages. It affirmed the civil indemnity and moral damages awarded to the heirs of the deceased jail guards, but increased the exemplary damages due to the presence of treachery. The court also adjusted the calculation of lost earning capacity to reflect annual rather than monthly income. The court deleted the award of moral damages in the carnapping case. Finally, the court imposed a legal interest rate of 6% per annum on all awarded damages from the date of finality of the judgment.

FAQs

What was the key issue in this case?	The key issue was whether the inmates could be convicted of murder and carnapping, considering their arguments of lack of treachery, insufficient evidence, and uncontrollable fear. The court examined the elements of these crimes and the validity of the defenses presented.
Can treachery exist in a prison setting?	Yes, the court held that treachery can exist even if the victims are armed, if they are caught off guard and unable to defend themselves. The critical factor is the unexpected nature of the attack that deprives the victim of any chance to retaliate.
What evidence was used to identify Fieldad as a participant in the killings?	The primary evidence was the testimony of Dionisio Badua, an inmate who witnessed Fieldad’s direct involvement in the assault. This was corroborated by circumstantial evidence, including a positive paraffin test for gunpowder residue.
What is required to prove conspiracy in this case?	To prove conspiracy, the prosecution needed to show that Fieldad and the other inmates had an agreement and a joint purpose to commit the crime. This was inferred from their coordinated actions before, during, and after the attacks.
What are the elements of carnapping?	The elements of carnapping are: (1) actual taking of the vehicle; (2) intent to gain; (3) the vehicle belongs to someone else; and (4) the taking is without the owner’s consent or through violence or intimidation.
What is the defense of uncontrollable fear?	The defense of uncontrollable fear applies when a person acts under the impulse of an uncontrollable fear of an equal or greater injury. The fear must be imminent, impending, and of such a nature as to induce a well-grounded apprehension of death or serious bodily harm.
Why did the court reject the defense of uncontrollable fear in the carnapping charge?	The court rejected the defense because the appellants had ample opportunity to escape and were not under such imminent threat that they had no choice but to participate in the carnapping. The circumstances did not support a genuine fear for their lives.
What damages were awarded in this case?	The court awarded civil indemnity, moral damages, and exemplary damages to the heirs of the deceased jail guards. It also awarded nominal damages to the owner of the carnapped vehicle, but deleted the award for moral damages. The court adjusted the lost earning capacity calculations and imposed a legal interest rate on all damages.

This case illustrates the complexities of establishing criminal liability within the confines of a prison and the high burden of proof required to successfully invoke defenses like uncontrollable fear. The Supreme Court’s decision underscores the principle that even in challenging environments, the law must be applied fairly and consistently to ensure justice is served.

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 vs. Charlie Fieldad, Ryan Cornista, and Edgar Pimentel, G.R. No. 196005, October 01, 2014