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	GR Nos. 131736-37 2002-03-11	PEOPLE v. JOEY MANLANSING Y AMBROSIO QUISUMBING, J.
We also find the award of P500,000 in moral damages excessive. Moral damages are not meant to enrich an injured party. In line with prevailing jurisprudence,[63] the award in each case should be reduced to P50,000. In addition, P50,000 as civil indemnity in each of these cases is mandatory and is granted to the heirs of the victims without need of further proof other than the commission of the crime.[64]
	GR No. 137050 2001-07-11	PEOPLE v. GEORGE CORTES Y ORTEGA PARDO, J.
"The trial court erred in further appreciating the aggravating circumstance of abuse of superior strength. Abuse of superior strength is absorbed in treachery, so that it can not be appreciated separately as another aggravating circumstance."[10] Here, treachery qualified the offense to murder.