People v. Narit

Summary

The Supreme Court modified the Regional Trial Court's murder conviction to homicide in this automatic review case. Accused Emilio Narit killed Timoteo Morales with a wooden club in April 1986. The trial court found murder based on evident premeditation (accused's prior expression of hatred) and treachery (sudden attack on elderly victim). The Supreme Court held that evident premeditation requires outward acts showing criminal intent, not mere expression of ill-will, and that the month-long gap between the expression of hatred and the killing, without more, was insufficient. Treachery was not established because the lone eyewitness did not observe how the attack commenced. The Court noted the crime occurred in broad daylight on a public road, suggesting a casual rather than planned encounter. The conviction was reduced to homicide with an indeterminate sentence under the Indeterminate Sentence Law, and civil indemnity was increased to P50,000.