Title
People vs. Bautista
Case
G.R. No. 131840
Decision Date
Apr 27, 2000
Accused-appellants Henry and Nilo Bautista are convicted of homicide for the killing of Igmidio Grajo, with the Supreme Court ruling that the allegation of self-defense was untenable and the existence of conspiracy between accused-appellants was proven based on the manner in which the offense was committed.
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Case Digest (G.R. No. 131840)

Facts:

  • On June 7, 1995, Richard Grajo, the son of Igmidio Grajo, was with a group of friends in front of a store in Tanay, Rizal.
  • Richard saw accused-appellants Henry and Nilo Bautista walking behind his father.
  • Igmidio ran inside a nearby house to avoid accused-appellants, but they pursued him.
  • Igmidio ran outside the house, and accused-appellants caught up with him.
  • Henry tried to stab Igmidio, but he was able to evade the thrust.
  • Richard came out of the store to help his father, but Nilo held him and punched him in the stomach.
  • Henry stabbed Igmidio several times, causing him to fall to the ground.
  • Accused-appellants then ran away.
  • Igmidio was taken to a hospital where he died.

Issue:

  • (Unlock)

Ruling:

  • The allegation of self-defense is untenable.
  • The existence of conspiracy between accused-appellants is proven.
  • ...(Unlock)

Ratio:

  • The trial court's evaluation of the testimony of witnesses is entitled to great respect.
  • Proof of motive is not essential when there is direct testimony regarding the commission of the offense, but it may aid in establishing guilt.
  • The defense failed to establish the allegation of self-defense.
  • Conspiracy may be deduced from the manner in which the offense is committed.
  • Treachery cannot be appreciated when the victim was given time to retreat after seeing his attackers.
  • Evident premeditation was not established.
  • The aggravating circumstance of abuse of superior strength is present.
  • Accused-appellant Henry Bautista is entitl...continue reading

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