PEOPLE OF THE PHILIPPINES, vs. TIRSO GARCIA and VICENTE TORREJAS, accused.
- G.R. Number: G.R. No. 94187
- Promulgated: 1992-11-04
- Ponente: Davide, Jr., J.
Doctrine
An accused is presumed innocent; only proof beyond reasonable doubt will overcome the presumption, and the prosecution must present reliable evidence to establish guilt.
Judges must employ correct legal terminology in imposing imprisonment penalties because terms like 'life imprisonment' and 'reclusion perpetua' have different legal accessories and effects.
Facts
Appellant Vicente Torrejas appealed from the RTC Branch 4, Bohol decision promulgated on 20 April 1990 in Criminal Case No. 5696, which convicted him of robbery with homicide and sentenced him to life imprisonment, ordered P30,000 legal indemnity and P5,600 reimbursement to heirs.
The appellate Court reviewed the evidence and found the prosecution presented only scant and unreliable evidence, insufficient to overcome the presumption of innocence.
The trial court used the term 'life imprisonment' although the penalty for robbery with homicide is reclusion perpetua under Article 294 of the RPC; the Court emphasized the distinction and correct legal terminology.
The Court reversed the RTC conviction and acquitted Vicente Torrejas, ordering his immediate release unless held for another lawful cause; costs were imposed de oficio.
Issues
Whether the prosecution proved the guilt of appellant beyond reasonable doubt for robbery with homicide.
Whether the trial court correctly imposed 'life imprisonment' as the penalty for robbery with homicide.
Ruling
The Court reversed the RTC conviction and acquitted appellant for lack of proof beyond reasonable doubt; ordered his immediate release unless held for another lawful cause and imposed costs de oficio.
The Court held that 'life imprisonment' is not the proper term for the penalty under Article 294 (robbery with homicide) and admonished judges to use the correct term 'reclusion perpetua' because of differing legal effects.
Keywords
G.R. No. 94187, robbery with homicide, life imprisonment, legal indemnity, Article 293 and 294 of the Revised Penal Code, Article 48 of the same Code, aggravating circumstances of abuse of superior strength, disregard of the respect due the offended party on account of his age, conspiring, confederating and mutually helping, intent to gain, violence or intimidation upon persons, willfully, unlawfully and feloniously take, steal and carry away, intent to kill, blunt instruments, physical injuries or mortal wounds, Philippine Currency, tsn june, flaviano, house, amount