In People v. Rolly Adriano y Samson, the Supreme Court affirmed the conviction of Rolly Adriano for murder and homicide, clarifying the application of aberratio ictus, or mistake in the blow. The Court held Adriano liable for the death of a bystander, Ofelia Bulanan, who was unintentionally killed by a stray bullet during Adriano’s assault on the intended victim, Danilo Cabiedes. This ruling underscores that a person committing a felony is responsible for all consequences that naturally result, regardless of intent, reinforcing accountability in criminal actions and offering protection to unintended victims.

When a Mistaken Blow Leads to Murder: Examining Intent and Consequence

The case revolves around an incident on March 13, 2007, in San Isidro, Nueva Ecija, where Rolly Adriano and others ambushed Danilo Cabiedes. During the attack, a stray bullet struck and killed Ofelia Bulanan, a bystander. Adriano was subsequently charged with two counts of murder for the deaths of both Cabiedes and Bulanan. The Regional Trial Court (RTC) convicted Adriano, a decision later affirmed by the Court of Appeals (CA). The central legal question is whether Adriano could be held liable for the death of Bulanan, whom he did not intend to harm, and whether treachery could be appreciated in the context of aberratio ictus.

The prosecution presented evidence that Adriano was part of a group that ambushed Cabiedes, firing multiple shots at his vehicle. Witnesses identified Adriano as one of the shooters. The defense argued alibi, claiming Adriano was elsewhere at the time of the incident. The RTC and CA both rejected the alibi, finding it unconvincing and insufficient to overcome the positive identification by prosecution witnesses. The Supreme Court then took up the appeal to clarify the extent of Adriano’s liability.

In its analysis, the Supreme Court emphasized that to secure a murder conviction, the prosecution must prove: a person was killed; the accused killed them; the killing was attended by any of the qualifying circumstances mentioned in Art. 248 of the Revised Penal Code; and the killing is not parricide or infanticide. The Court found that all these elements were met concerning both Cabiedes and Bulanan. For Cabiedes, the Court highlighted the presence of treachery, defined in Article 14 of the Revised Penal Code as:

Paragraph 16 of Article 14 of the Revised Penal Code (RPC) defines treachery as the direct employment of means, methods, or forms in the execution of the crime against persons which tend directly and specially to insure its execution, without risk to the offender arising from the defense which the offended party might make.

The Court noted that the ambush ensured Cabiedes had no chance to defend himself. The essence of treachery is the sudden and unexpected attack on an unsuspecting victim, depriving the latter of any chance to defend himself and thereby ensuring its commission without risk of himself. This element qualified the killing of Cabiedes as murder.

Regarding Bulanan’s death, the Court invoked the doctrine of aberratio ictus, as outlined in Article 4 of the Revised Penal Code: “Criminal liability shall be incurred by any person committing a felony (delito) although the wrongful act done be different from that which he intended.” The Court reasoned that even though Adriano did not intend to kill Bulanan, her death was a direct consequence of his unlawful act of shooting at Cabiedes. The Court quoted People v. Herrera, stating, “[t]he fact that accused killed a person other than their intended victim is of no moment.” This principle underscores that a person is responsible for all the consequences of their felonious actions.

Building on this principle, the Court affirmed the applicability of treachery even in cases of aberratio ictus, citing People v. Flora. This means that even though Bulanan was not the intended victim, the sudden and unexpected nature of being struck by a stray bullet, which precluded any possibility of self-defense, satisfied the element of treachery. The Court also dismissed Adriano’s alibi, noting that it was not physically impossible for him to be at the crime scene, given its proximity to his claimed location at the time of the incident. Furthermore, the Court found that the alibi was corroborated only by relatives and friends, which diminished its credibility.

The Court distinguished this case from a complex crime, emphasizing that the deaths of Cabiedes and Bulanan were the result of separate acts, not a single act. The recovery of multiple bullet cartridges indicated separate shots, each constituting a distinct crime. Therefore, Adriano was convicted of two separate counts of murder. The Supreme Court modified the award of actual damages, increasing it to P232,482.00 based on the presented official receipts. The Court also awarded civil indemnity, moral damages, and exemplary damages to the heirs of both victims.

The practical implications of this ruling are significant. It reinforces the principle that individuals who commit intentional felonies are responsible for all resulting consequences, even if those consequences are unintended. This provides a measure of justice for victims of stray bullets or other unintended harm, ensuring that perpetrators are held accountable. The application of treachery in aberratio ictus further underscores the gravity of the offense, recognizing the defenselessness of the unintended victim. The ruling also serves as a deterrent, discouraging reckless behavior that could result in harm to innocent bystanders.

FAQs

What is ‘aberratio ictus’?	Aberratio ictus is a legal term that refers to a mistake in the blow, where the intended victim is not harmed, but another person is injured or killed instead. The perpetrator is still held liable for the resulting harm to the unintended victim.
What was the key issue in this case?	The key issue was whether Adriano could be held liable for the death of Ofelia Bulanan, an unintended victim, under the doctrine of aberratio ictus, and whether treachery could be appreciated in such a case.
What is ‘treachery’ in the context of this case?	Treachery, in this context, refers to the deliberate and unexpected nature of the attack, which ensures the victim has no opportunity to defend themselves. This element elevates the crime to murder.
How did the court apply the doctrine of ‘aberratio ictus’ in this case?	The court applied the doctrine by holding Adriano responsible for Bulanan’s death because it was a direct consequence of his intentional act of shooting at Cabiedes. The intent to harm Cabiedes transferred to the unintended victim, Bulanan.
Why was Adriano’s alibi rejected by the court?	Adriano’s alibi was rejected because it was not physically impossible for him to be at the crime scene at the time of the incident. Also, his alibi was corroborated only by relatives and friends, which the court deemed insufficient.
What was the significance of finding ‘treachery’ in Bulanan’s death?	Finding treachery meant that Bulanan’s death was qualified as murder, even though she was an unintended victim. This recognition underscored the gravity of the offense due to the defenselessness of Bulanan.
What damages were awarded to the heirs of the victims?	The heirs of Danilo Cabiedes were awarded civil indemnity, moral damages, exemplary damages, and actual damages. The heirs of Ofelia Bulanan were awarded civil indemnity, moral damages, exemplary damages, and temperate damages in lieu of actual damages.
How does this ruling affect future cases involving unintended victims?	This ruling reinforces the principle that perpetrators are responsible for all consequences of their felonious acts, even if unintended. It provides a legal basis for holding criminals accountable for harm caused to unintended victims.

In conclusion, the Supreme Court’s decision in People v. Rolly Adriano y Samson clarifies and reinforces the application of the doctrine of aberratio ictus in Philippine law. The ruling underscores that individuals are responsible for the consequences of their actions, even when those consequences extend to unintended victims. This decision provides a measure of justice for victims of stray bullets or other unintended harm, ensuring that perpetrators are held accountable for their actions.

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. Rolly Adriano y Samson, G.R. No. 205228, July 15, 2015