The Supreme Court held that an information (or charge) is sufficient even if it does not explicitly cite the specific article of the Revised Penal Code defining the crime, as long as it clearly states the essential elements of the offense. This means a person can be validly convicted of a crime, like homicide, even if the charge sheet does not mention the specific penal code section, provided the charge includes the act (stabbing), intent (to kill), and result (death). The ruling focuses on ensuring that accused persons are fully informed of the charges against them, regardless of technical citations.
Can a Homicide Conviction Stand Without Explicit Reference to Article 249 of the Revised Penal Code?
This case stems from an incident on February 16, 1992, in Kiangan, Ifugao, where Rufino Guay was fatally stabbed. Roberto Licyayo was charged with homicide and direct assault following the event. The central issue revolves around whether the information filed against Licyayo for homicide was deficient because it did not specifically cite Article 249 of the Revised Penal Code. Licyayo contended that this omission violated his constitutional right to be informed of the nature and cause of the accusation against him. He argued that the charge’s failure to expressly refer to “homicide as defined and penalized under Article 249 of the Revised Penal Code” rendered it inadequate for preparing his defense.
The Court turned to the Revised Rules of Criminal Procedure to resolve the matter. Section 6, Rule 110 requires an information to contain the accused’s name, the offense’s designation by statute, the acts or omissions constituting the offense, the offended party’s name, the approximate date of commission, and the place of occurrence. Similarly, Section 8, Rule 110 mandates the information to state the designation of the offense, detail the acts or omissions constituting the offense, and specify its qualifying and aggravating circumstances. The Court emphasized that nothing in these rules specifically requires an information to cite the particular law under which the accused is charged. As long as the information designates the offense and specifies the acts constituting it, it meets the basic requirements.
The Supreme Court referenced People v. Gatchalian, which affirmed that there is no legal requirement to mention the specific penalizing provision in the information for a conviction to be valid. More importantly, the character of the crime is derived from the recital of ultimate facts and circumstances in the information, rather than the caption, preamble, or specific law cited. This ruling underlines the principle that the core elements of the offense must be clear in the description of the facts. For example, even though the information didn’t specifically cite Article 249, it described Licyayo stabbing Rufino with a bladed weapon, resulting in death—clearly indicating homicide under Article 249.
Regarding the mitigating circumstances, Licyayo argued sufficient provocation because Rufino allegedly punched Licyayo’s brother, Aron, first. Additionally, he claimed intoxication, stating it was affirmed by officers in their testimonies and was not subsequent to any plan to commit a felony. However, the Court determined that there was no convincing evidence regarding who initiated the brawl. Absent a clear origination of provocation from Rufino, the mitigating circumstance of sufficient provocation was not applicable. Furthermore, the Court found no evidence suggesting Licyayo’s mental faculties were impaired. Licyayo vividly recalled details from the event, demonstrating that he was fully conscious of his actions, thus precluding intoxication as a mitigating factor.
The Court addressed the sentence, noting that homicide is punishable by reclusion temporal. There were no aggravating or mitigating circumstances, the penalty was applied in its medium period of 14 years, 8 months, and 1 day to 17 years and 4 months. Consequently, the Supreme Court upheld the award of civil indemnity of P50,000 and moral damages of P50,000 to the heirs of Rufino. Additionally, the appellate court’s award of P25,000 for temperate damages and P580,050 for lost earnings was deemed appropriate.
FAQs
| What was the key issue in this case? | The key issue was whether the information charging Roberto Licyayo with homicide was defective because it did not explicitly cite Article 249 of the Revised Penal Code. The court addressed whether such omission violated Licyayo’s right to be informed of the charges against him. |
| What does it mean for an information to be “sufficient”? | An information is considered sufficient if it states the name of the accused, the designation of the offense, the acts or omissions constituting the offense, the name of the offended party, and the date and place of the crime. The information must allow the accused to understand the charges and prepare a defense. |
| Why did the Court rule that the lack of a specific code citation was not fatal? | The Court ruled that the crucial aspect of the information is the clear recital of the facts and circumstances constituting the offense, rather than the citation of the specific penal code article. The facts presented in the information clearly described the crime of homicide, which made the charge valid. |
| What is the role of the Revised Rules of Criminal Procedure in this ruling? | The Revised Rules of Criminal Procedure dictate the necessary elements of a sufficient information, emphasizing the need for clear designation of the offense and details of the actions constituting the crime. They do not explicitly require the citation of a specific penal code article. |
| What constitutes “sufficient provocation” as a mitigating circumstance? | Sufficient provocation requires proof that the victim’s actions directly incited the accused and immediately preceded the act complained of. Here, since the origination of the brawl was not definitively traced to the victim, this mitigating circumstance could not be applied. |
| How is “intoxication” viewed as a mitigating circumstance? | For intoxication to be a mitigating circumstance, the accused must prove that the amount of alcohol consumed significantly impaired their mental capacity, such that they did not understand their actions or their wrongfulness. Simply being intoxicated is not enough. |
| What kind of damages were awarded in this case? | The Court awarded civil indemnity, moral damages, temperate damages, and compensation for loss of earning capacity to the heirs of the deceased. Civil indemnity and moral damages were each set at P50,000, temperate damages at P25,000, and loss of earning capacity was calculated at P580,050. |
| What evidence is required to prove loss of earning capacity? | Ideally, documentary evidence of the victim’s annual income is required to prove loss of earning capacity. However, testimonial evidence can suffice if the victim was self-employed earning less than minimum wage, or if they were a daily-wage worker. |
This ruling clarifies the requirements for a sufficient information in criminal proceedings, highlighting the importance of clearly stating the essential elements of an offense over strict adherence to citing specific legal articles. By ensuring that accused persons are informed of the substance of the charges against them, the Supreme Court continues to uphold the principles of due process and fairness in the Philippine justice system.
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: Licyayo v. People, G.R. No. 169425, March 04, 2008