G.R. No. 27200 - People vs. Bustos

On October 24, 1925, a dispute arose between Francisco Bustos and Angel del Castillo over the boundaries of their lands on the Guadalupe Estate.
The quarrel escalated with Francisco Bustos grabbing Angel del Castillo by the neck.
Mariano Montemayor and his ward, Antonio Macaspac, intervened to separate the combatants; Montemayor restrained Angel del Castillo, and Macaspac held Bustos.
Bustos was taken to his house by Macaspac, while Angel del Castillo’s wife, Laureana Yumul, left the scene and heard her deaf-mute daughter’s distressed signs.

Laureana Yumul followed her daughter's indications and found her son, Felipe del Castillo, lying wounded and shortly thereafter dying.
The autopsy by Dr. Eugenio Santos revealed multiple wounds on Felipe’s left arm, and a fatal penetrating wound below the sternum involving the stomach.
That same night, Bustos presented himself to the municipal president with a forehead wound, claiming he had been stoned. He was admitted to the General Hospital.

Laureana Yumul testified that Felipe named Francisco Bustos and Antonio Macaspac as his assailants before dying.
The municipal president Nicanor Garcia and Cristino Basay contradicted Yumul, stating that she had asked them who killed her son—a claim Yumul denied. The court found Yumul’s testimony more credible.
Mariano del Castillo, Felipe’s younger brother, testified to seeing Felipe being pursued by Bustos (armed with a dagger) and Macaspac (armed with a bolo).
Testimony from Soledad Encarnacion, the deaf-mute daughter of Laureana Yumul, was interpreted by a teacher who had no prior contact or teaching relationship with her, casting doubt on its reliability.

Francisco Bustos claimed that Angel del Castillo with Felipe, Delfin, and Laureana Yumul had threatened to kill him, followed him to his house, where he acted in self-defense, stabbing someone while being struck in the forehead with a bolo.
Contradictions arose as Bustos initially stated he was stoned outside his home, and bloodstains in his house did not corroborate his account of the fatal stabbing inside.
Antonio Macaspac raised an alibi, claiming absence from Guadalupe from 6:30 PM to 11:30 PM, having gone to Manila.
The time of Felipe’s wounds and death (before nightfall) made Macaspac’s alibi suspicious, possibly fabricated after the event.

The pattern of wounds (sharp and pointed) aligns with the testimony describing weapons used by Bustos and Macaspac, corroborating the prosecution’s version.
The court concluded that both accused, as principals, pursued and inflicted fatal wounds upon Felipe del Castillo, resulting in his death, constituting homicide under Article 404 of the Penal Code.

Whether the lower court erred in convicting Antonio Macaspac beyond reasonable doubt as co-principal in the homicide of Felipe del Castillo.
Whether the alibi presented by Antonio Macaspac was sufficiently proven to exonerate him.
Whether the lower court erred in relying principally on the testimonies of a deaf-mute witness interpreted by a teacher with no prior relationship with her, and on certain findings about Bustos’ admissions and physical evidence.
Whether there was sufficient evidence to convict Francisco Bustos of homicide and sentence him to reclusion temporal.