Case Digest (G.R. No. 55285)
Facts:
People of the Philippines v. Sixto Bayocot y Saguing, G.R. No. 55285, June 28, 1989, Supreme Court Second Division, Sarmiento, J., writing for the Court.The prosecution charged Sixto Bayocot y Saguing (appellant/defendant) with the murder of Gracia Cabrera Dumont. The Circuit Criminal Court in Tagbilaran City, Bohol rendered a decision on April 28, 1980 finding the appellant guilty of murder qualified by treachery, sentencing him to reclusion perpetua, ordering indemnities to the heirs, and confiscating the bolo used as the instrument of the crime. The trial court's factual findings described events of June 25, 1979: after attending hearings of cases Mrs. Dumont filed against the Bayocots, Mrs. Dumont and companions rode a sled pulled by a carabao toward her farmhouse; a person wearing boots and a red raincoat emerged from the farmhouse and, after allowing the sled to pass, the person (identified as Sixto Bayocot) allegedly stabbed Mrs. Dumont twice with a long bolo, causing fatal wounds, and then fled. At 4:30 p.m. the same day the appellant surrendered to police, admitted the killing, and handed over the bolo.
At trial the appellant testified that he had entered Mrs. Dumont’s land to look for a lost carabao and that Mrs. Dumont scolded him and acted as if reaching into her bag, prompting him to stab her in self-defense; he also admitted the two stabbings but denied hiding his bolo. The trial court rejected self-defense, concluded the killing was motivated by vengeance relating to prior civil and criminal suits between the families, and found treachery and an aggravating circumstance of disregard of age and sex. On appeal to the Supreme Court, t...(Subscriber-Only)
Issues:
- Did the trial court err in refusing to entertain the appellant’s claim of self-defense?
- Was the trial court correct in appreciating the qualifying circumstance of treachery?
- Was the trial court correct in finding the aggravating circumstance of disregard of age and sex?
- Was the appellant properly convicted of murder and is t...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)