G.R. No. 113940 - People vs. Buluran y Ramirez

On May 16, 1993, the Meyer family was celebrating the birthday of the matriarch at their residence in Area 4, Barangay Amaparo, Capri, Novaliches, Quezon City.
An altercation erupted between family members when Dominador Meyer, Jr. quarreled with a cousin during the celebration.
Edilberto Meyer, Sr., the victim, attempted to pacify the dispute by bringing Dominador outside the house to cool off.

While Edilberto Meyer, Sr. and Dominador were conversing outside, Reynaldo Danao intervened by warning them not to cause trouble during the ongoing fiesta.
The victim denied any intent to quarrel, attributing the disturbance to family issues.
A physical altercation ensued between Reynaldo and the victim, during which a boxing blow was exchanged; Reynaldo managed to flee but soon returned.

Upon his return, Reynaldo Danao was accompanied by his gangmates—Cielito Buluran, Leonardo Valenzuela, and Jaime Danao—armed with various deadly weapons:

Reynaldo wielded a 12-inch stainless steel knife.
Cielito Buluran was also armed with a knife.
Leonardo and Jaime each carried slingshots loaded with sharp arrows (five-inch nails with abaca tails).

Without warning, Reynaldo stabbed the victim on the left side of his lower back while his companions used their weapons to deter any interference from bystanders.
The combined presence of the assailants ensured that no one from the gathering could render aid, and the four then fled the scene.
The victim died later that same night as a direct consequence of the stabbing.

On May 20, 1993, appellant Cielito Buluran, along with three unnamed individuals (John Does), was charged with the crime of murder under an Information which later was amended to include Leonardo Valenzuela.
The trial court proceedings saw the presentation of several pieces of evidence:

Testimonies of three eyewitnesses—Artemio AvendaAo, Jacinto Castillo, and Gloria Castillo—who were neighbors of the victim.
Testimony of police personnel (PO1 Roberto C. San Miguel and Chief Inspector Florante F. Baltazar) who corroborated aspects of the incident, including the autopsy report indicating a fatal stab wound to the posterior left lumbar region.
The victim’s widow, Mrs. Erlinda C. Meyer, testified regarding the actual damages incurred.

Both accused claimed they were asleep in their respective homes at the time of the incident.
The father of appellant Buluran and Manuel Valenzuela testified to corroborate the alibi, with Manuel also recounting a separate fight involving Reynaldo Danao and other individuals.
Dr. Feliciano Bornales testified regarding the treatment of Reynaldo Danao’s stab injuries, without ascribing responsibility for the wounds.

Based on the evidence, the trial court convicted the accused for murder, finding elements of conspiracy and qualifying circumstances such as treachery, and sentenced them to suffer reclusion perpetua along with indemnity and damage payments to the victim’s heirs.

The appellants contended that they were scapegoated for the killing and asserted that they are law-abiding citizens with no previous police records.
They raised claims of violations of their constitutional and procedural rights, particularly:

The absence of counsel during custodial investigation.
Their arrest without a warrant and without a preliminary investigation by the City Prosecutor.

The accused argued that these irregularities should entitle them to an acquittal or, at minimum, mitigate the gravity of their conviction.

Whether the appellants were estopped from raising issues regarding the validity of their arrest because they did not object to arrest-related irregularities prior to their arraignment.
Whether the failure to have counsel present during custodial investigation violated their constitutional right to a fair process, especially in light of the absence of any extrajudicial confession extracted from them.
Whether the lack of a preliminary investigation, which is a substantive right of the accused, invalidated the trial proceedings given that the issue was raised only on appeal.

Whether the elements of the crime of murder were properly established including the allegations of treachery and evident premeditation, or if the crime committed should be reclassified as homicide.
Whether the presence of conspiracy among the accused, even if only one (Reynaldo Danao) actually stabbed the victim, was sufficient to establish their complicity in the killing.
Whether the aggravating circumstance of abuse of superior strength was appropriately applied given the collective action of the assailants.