Title
People vs. Bustos
Case
G.R. No. 17763
Decision Date
Jul 28, 1923
A prominent municipal president, Proceso Bustos, and accomplices assaulted and fatally stabbed his cousin, Liborio Bustos, during a circus, driven by personal and political animosity. The Supreme Court upheld their homicide conviction, citing superior strength and credible evidence.
A

Case Digest (G.R. No. 253305)

Facts:

On June 19, 1920, in the municipality of Macabebe, Pampanga, Liborio Bustos was assaulted during a traveling circus and died about June 21, 1920, from a fatal dagger wound to the left side of his abdomen, with perforation of the stomach. Proceso Bustos, then municipal president, together with Felipe Bustos, Jose Blanco, Filomeno Sunga, Donato Benosa, and Irineo Cailao were convicted by the Court of First Instance of the Province of Pampanga of homicide, with the aggravating circumstance of advantage taken of superior strength, and each was sentenced to reclusion temporal of seventeen years, four months, and one day, plus indemnity and costs. Three others named in the information were acquitted and were not part of the appeal.

The prosecution relied heavily on an ante mortem statement executed by the victim at about 1:40 a.m. of June 20, 1920, in contemplation of approaching death, and on corroborating testimony concerning the circumstances of its signing and contents. The defense attacked the statement as fabricated and claimed another person, Pablo Ocampo, inflicted the fatal wound. The case was considered together with a related prosecution against Ocampo, after the Court ordered the record be returned to the lower court for additional proof on the authenticity of the statement.

Issues:

  • Whether the conviction of the six appellants for homicide was supported by proof beyond reasonable doubt, particularly in light of the challenged ante mortem statement of Liborio Bustos.
  • Whether premeditation and alevosia were established to qualify the offense as murder.
  • Whether the other named persons’ participation could be inferred so as to hold all six liable, and whether advantage taken of superior strength was properly appreciated.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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