Case Digest (G.R. No. 93851)
Facts:
In the case of Mark Bayquen vs. The Court of Appeals and The People of the Philippines, G.R. No. 93851, decided on March 6, 1992, the petitioner, Mark Bayquen, along with co-accused Wilfredo Boco, was charged with homicide under Article 249 of the Revised Penal Code. The information was filed by Jose P. Basco, Assistant City Fiscal, alleging that on July 25, 1984, in Baguio City, the accused conspired to attack Teofilo Estepa, resulting in his death due to cardio-respiratory failure caused by a gunshot wound. Both accused pleaded not guilty during their arraignment.
The trial court rendered its decision on December 15, 1989, finding Bayquen and Boco guilty of homicide instead of murder, sentencing them to an indeterminate prison term and ordering them to pay damages to the victim's heirs. Boco appealed the decision, raising several errors regarding the credibility of the witness Bernadette Estepa, the victim's sister, and the admission of the victim's dying d...
Case Digest (G.R. No. 93851)
Facts:
Background of the Case
- Wilfredo Boco and Mark Bayquen were charged with Homicide under Article 249 of the Revised Penal Code for the death of Teofilo Estepa on July 25, 1984, in Baguio City.
- The prosecution alleged that the accused, armed with a gun and a bladed weapon, attacked and killed Teofilo Estepa, causing cardio-respiratory failure due to massive hemorrhage and gunshot wounds.
Events Leading to the Incident
- On July 23, 1984, Teofilo Estepa returned home and told his sister, Bernadette Estepa, that he had been "led into trouble" but did not elaborate.
- On July 24, 1984, Barangay Captain Albert Della and Dr. Bayquen (Mark Bayquen’s father) visited the Estepa residence, looking for Teofilo. They warned that if he did not show up, they would pick him up the next morning.
- Teofilo left the house at 8:00 p.m. to look for Wilfredo Boco, his companion in a motorcycle incident, but returned at 10:00 p.m., unable to find him.
The Incident
- On July 25, 1984, at around 4:00 a.m., Bernadette Estepa heard a commotion and found her brother, Teofilo, lying face down at the stair landing, bleeding. He told her, "They shot and stabbed me," and identified Mark Bayquen and Wilfredo Boco as his assailants.
- Bernadette helped Teofilo to their apartment and attempted to call the police. Teofilo was later taken to the hospital but was pronounced dead on arrival.
Post-Incident Developments
- Bernadette did not immediately report the dying declaration to the police. She revealed it 14 days later, on August 8, 1984.
- The autopsy revealed that Teofilo died from a single gunshot wound, not from stabbing as he had claimed in his dying declaration.
Trial Court Decision
- The trial court convicted both accused of Homicide, sentencing them to imprisonment and ordering them to pay damages to the victim’s heirs.
- Both Boco and Bayquen appealed the decision, raising several errors, including the credibility of Bernadette’s testimony and the admissibility of the dying declaration.
Issue:
- Whether the trial court erred in giving full credence to Bernadette Estepa’s testimony and the alleged dying declaration of Teofilo Estepa.
- Whether the dying declaration should be considered part of the res gestae.
- Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
- Whether the trial court erred in ignoring the defense’s evidence, including the lack of motive and the presence of a robbery in progress.
- Whether the judge who rendered the decision was the same judge who heard Bernadette Estepa’s testimony.
Ruling:
The Supreme Court reversed the decision of the trial court and acquitted Mark Bayquen on the ground of reasonable doubt. The Court found that the dying declaration of Teofilo Estepa, as testified by Bernadette Estepa, was unreliable due to its belated disclosure and inconsistencies with the autopsy findings. The Court also noted that Bernadette’s failure to report the dying declaration immediately and her contradictory statements to other witnesses undermined her credibility.
Ratio:
Dying Declaration Not Credible: The Court held that the dying declaration was not credible because it was disclosed 14 days after the incident, and Bernadette’s explanation for the delay (fear of being alone) was inconsistent with her actions during the incident. The Court cited the case of People v. Hernandez, where a similar delay in disclosing a dying declaration led to its rejection.
Res Gestae Rule Not Applicable: The Court ruled that Bernadette’s immediate statements to the police and the doctor, which did not identify the accused, were more credible and spontaneous than her later testimony. These earlier statements were consistent with the res gestae rule, while her later testimony was not.
Inconsistencies in Evidence: The autopsy report showed that Teofilo died from a single gunshot wound, contradicting his dying declaration that he was both shot and stabbed. This inconsistency further weakened the prosecution’s case.
Lack of Motive and Conspiracy: The Court found no evidence of motive or conspiracy between the accused. The prosecution’s theory that the accused killed Teofilo due to a dispute over a damaged motorcycle was unsupported by evidence.
Reasonable Doubt: Given the lack of credible evidence and the inconsistencies in the prosecution’s case, the Court concluded that the guilt of the accused was not proven beyond reasonable doubt.
Conclusion:
The Supreme Court acquitted Mark Bayquen due to the prosecution’s failure to prove his guilt beyond reasonable doubt. The Court emphasized the importance of timely and credible evidence in criminal cases, particularly when relying on dying declarations.