G.R. No. 113804 - People vs. Bato

On or about May 9, 1988, in the Municipality of Pastrana, Leyte, the victim, Ernesto Flores, Sr., was allegedly attacked, tied, and later found dead with multiple stab and hacking wounds.
The accused, Sergio Bato and Abraham Bato, were charged with murder under Article 248 of the Revised Penal Code, with the crime characterized by treachery, evident premeditation, and the use of deadly weapons (asundanga).
An Information filed by the Leyte Provincial Prosecutor detailed that the accused conspired, confederated, and mutually helped each other in the commission of the crime.

On January 15, 1990, both accused were arraigned (in the Waray dialect) and pleaded not guilty.
After a due trial, the trial court rendered a decision convicting both Sergio and Abraham Bato beyond reasonable doubt, basing its verdict largely on circumstantial evidence.
The trial court imposed a sentence under reclusion temporal (with adjustments in view of the abolition of the death penalty), applying the Indeterminate Sentence Law with accessory penalties including indemnification to the heirs of the deceased.

Both accused appealed the trial court’s decision.
The Court of Appeals, on January 26, 1994, affirmed the conviction but increased the penalty to reclusion perpetua, citing relevant precedents in People vs. Benitez, Jr. and People vs. Muñoz.
Pending the appeal, Sergio Bato died while in detention, thereby narrowing the appeal in this case solely to Abraham Bato.

The prosecution’s case rested primarily on circumstantial evidence, notably the testimony of Ernesto Flores, Jr., the son of the victim, who provided an account of the events before, during, and after the crime.
Dr. Virisimo Opiniano, the Municipal Health Officer, conducted the autopsy on the victim’s body, revealing multiple hacking and stabbing wounds, thus supporting the claim of a violent assault.
Additional testimony from Pfc. Benjamin Montanejos was introduced to address discrepancies regarding the police blotter entry and to counter the defense’s argument about the identification of the accused.

The defense maintained a strong denial of the allegations, asserting that the identification of the accused was a post hoc inference based on weak and uncorroborated circumstantial evidence.
The defense argued that significant gaps existed in the prosecution’s timeline, particularly regarding the actual events between the victim being tied and the discovery of his body.
It was contended that the absence of direct eyewitness testimony and the inconsistencies in the prosecution evidence (such as the police blotter entry and the circumstances around the victim’s demise) failed to unequivocally establish the accused’s guilt.

The case was evaluated in the context of other decisions involving similar circumstantial evidence issues (e.g., People vs. Roluna, People vs. Argawanon, and People vs. Ragon) where the need for corroborative details was underscored.
The jurisprudence stressed that a conviction based solely on circumstantial evidence requires an unbroken chain of proven events, which in this case, the prosecution failed to provide.
The decision emphasizes that any lapse in proving a clear and consistent narrative consistent with the accused’s guilt necessitates an acquittal.

Whether the circumstantial evidence presented, in the absence of a direct eyewitness, suffices to establish the guilt of the accused beyond a reasonable doubt.
Whether the evidence forms an unbroken and corroborated chain that excludes any hypothesis other than the guilt of the accused.
Whether the trial court and the Court of Appeals erred in relying predominantly on the testimony of Ernesto Flores, Jr., despite evident lapses and inconsistencies in the narrative.
Whether the increased penalty (from reclusion temporal to reclusion perpetua) imposed by the appellate court was justified given the nature and quality of the evidence.
Whether the constitutional presumption of innocence was effectively upheld in light of the prosecutorial shortcomings in proving the accused’s guilt.