G.R. No. 111149 - People vs. Bautista

The case involves the charge of murder against accused-appellant Renato Bautista and his three co-accused, namely Arman Hernandez, Arnold Mendoza, and Jess Sabarin, under an Information dated February 28, 1990.
The Information alleges that on or about December 14, 1989, in the City of Manila, the accused, acting in concert, attacked the victim, Rodel Yarza, with a bladed weapon inflicting a fatal stab wound.
The charge specifically notes that the killing was committed “wilfully, unlawfully and feloniously” with intent to kill by means of superior strength and violent force.

On March 26, 1990, warrants of arrest were issued against all the accused; however, only Renato Bautista was apprehended while his three co-accused remained at large.
During arraignment, accused-appellant Bautista pleaded “Not Guilty” to the charge.
The trial proceeded solely against Renato Bautista, culminating in a judgment on June 1, 1993, which found him guilty of murder, sentencing him to reclusion perpetua along with accessory penalties, restitution to the victim’s heirs, and imposition of costs.

Rodel Yarza, after selling merchandise, returned home and later joined a card game with the accused.
At around 9:00 p.m., a scuffle ensued in which Rodel was chased, assaulted, and ultimately stabbed.
Eyewitness testimony (e.g., from Charlie Yarza) confirmed that the victim was mauled and continued to be pursued, with details indicating that the fatal wound was inflicted by Renato Bautista.
The victim’s wife, Zenaida, later provided testimony recounting a dying declaration where Rodel identified “Rene” (Renato Bautista) as the one who stabbed him.

Renato Bautista admitted to playing cards on the night of the incident but claimed that when he was hit with a bottle on the head by the victim, he opted to return home rather than engage in a fight.
He asserted that upon returning, he discovered his co-accused engaging in a violent altercation with Rodel Yarza.
According to his account, his mother intervened, preventing him from joining the melee, thereby distancing his role from the subsequent stabbing.

Charlie Yarza provided a detailed account of the events including seeing Renato Bautista, along with the other accused, chasing and eventually assaulting the victim.
His testimony established a timeline, identifying the presence and actions of each accused during the incident.

The victim, Rodel Yarza, in his final moments, allegedly identified his assailants when questioned by his wife, Zenaida.
The declaration, though not explicitly acknowledging impending death, was deduced to be made under the consciousness of impending death due to the victim’s physical condition (pale, weak, and sweating profusely) and the eventual fatal outcome.

Dr. Marcial G. CeAido, the medico-legal officer, testified on the findings of the necropsy, describing a penetrating stab wound that punctured the lower lobe of the left lung, causing fatal hemorrhage and shock.

The trial court found that the use of “abuse of superior strength” by the assailants qualified the killing as murder.
Although the evidence of evident premeditation was examined, the court noted that while such aggravating circumstance was considered, it was countered by the mitigating circumstance of provocation.
On appeal, the defense disputed the characterization of the victim’s dying declaration and the determination of premeditation, but the appellate court sustained the conviction based primarily on direct and corroborated evidence.

Despite the conflicting versions from the prosecution and the accused, the weight of direct evidence—from eyewitness testimonies, the dying declaration, and corroborative statements (including that of Efren Bautista regarding the accused’s unusual behavior)—supported the finding of guilt.
The court, noting the absence of sufficient evidence to prove a deliberate and extended period of premeditation, nonetheless upheld the conviction based on the established evidence of collective force and violent conduct.

Whether the victim’s dying declaration, as relayed by his wife Zenaida Yarza, satisfies the legal requirements under Section 37, Rule 130 to be admissible as evidence despite the victim not explicitly stating his awareness of impending death.
Whether the testimonial and medical evidence sufficiently links accused-appellant Renato Bautista to the crime of murder, considering the conflicting accounts between the prosecution and the accused’s version of events.
Whether the trial court erred in considering the aggravating circumstance of evident premeditation in light of the evidence which shows only a brief lapse between the initial altercation and the further violent act.
Whether the evidence of abuse of superior strength and the circumstances surrounding the attack justify qualifying the killing as murder despite the defense’s contention of provocation and the absence of a prolonged plan.