G.R. No. 127843 - People vs. Bato

On August 16, 1995, during the town fiesta in Barangay Pansil, Malitbog, Southern Leyte, a group of friends was engaged in celebratory activities that included drinking and socializing.
The parties present included the victim Reynaldo Sescon, prosecution witness Rogelio Conato, and the accused Jacinto D. Bato and Herman D. Bato.
Events unfolded in the early morning after a night of heavy drinking.

After having breakfast at Gabriel Bulac’s house and going to the house of Carlos Cadayona, Reynaldo joined his companions at the balcony where they were drinking Tanduay Rum.
Reynaldo invited Rogelio Conato to join their conversation and drinking session, contributing to a relaxed, jovial atmosphere.
Despite the friendly mood, the group had been drinking since the previous evening and was substantially intoxicated.

During the social gathering on the balcony, Jacinto D. Bato unexpectedly struck Reynaldo with an almost empty Tanduay Rum bottle.
In response, Herman D. Bato urged his brother by saying “Patyon ta ni” (“We will kill him”) and subsequently stabbed Reynaldo on his left breast.
The stabbing occurred while Reynaldo was distracted, defenseless, and in a position where he could not effectively respond—his raised hands and pleas indicating his vulnerability.
Witnesses, including Virgilia Cadayona, observed Herman’s stabbing, and the post-mortem examination later confirmed that Reynaldo sustained fatal injuries due to massive bleeding resulting from severed major blood vessels (notably the pulmonary and bronchial arteries).

The Regional Trial Court, Southern Leyte, Maasin, found both Herman and Jacinto guilty beyond reasonable doubt of murder.
The decision imposed reclusion perpetua on Herman as the principal perpetrator and a lesser penalty on Jacinto as an accomplice, including joint civil liabilities such as payment of civil indemnity and moral damages to the victim’s heirs.
Following their separate arraignments and pleas of “not guilty” on November 8, 1995, the accused invoked an appeal which was accepted on October 17, 1997, challenging various aspects of the trial court’s findings.

Whether or not there was a conspiracy between the accused to kill Reynaldo Sescon.

The determination centered on whether the actions of both accused demonstrated a mutual agreement or a common plan to commit murder.

This issue involved assessing if the manner of the killing—taking advantage of the victim’s defenseless state—fit the legal requirements for treachery under the Revised Penal Code.

The credibility of witness testimonies, especially that of Rogelio Conato, and the overall factual matrix were scrutinized to uphold the conviction.

Whether or not the accused-appellants could validly claim the privileged mitigating circumstance of “incomplete self-defense.”

The Court examined if the evidence supported a self-defense claim, considering the absence of unlawful aggression by the victim.