G.R. No. L-50276 - People vs. Butler

Michael J. Butler, accused-appellant, a seaman of the U.S. Navy, was charged with murder qualified by abuse of superior strength with the aggravating circumstances of treachery and scoffing at the corpse of Enriquita Alipo alias "Gina Barrios," in Olongapo City on or about August 8, 1975.
The Information detailed that Butler assaulted the victim by hitting her with a statue of Jesus Christ and thereafter suffocated her by forcing her mouth and nose against the mattress, causing her death.

On August 7, 1975, Butler was seen with the victim at Colonial Restaurant and then arriving together at the victim’s house around 11:30 p.m.
Victim copied Butler’s name and ID number on a piece of paper, expecting he would leave.
The next morning at 4:00 a.m., their housemaid found the victim dead, lying face down on the bed with a broken figurine beside her head.
Patrolman de los Reyes and Fiscal Llamado arrived and secured the crime scene.

Fingerprint expert Jesus Bensales matched a latent print from the broken figurine’s cellophane wrapper to Butler’s fingerprint.
Butler was identified as a suspect and taken off the USS Hancock by Naval Intelligence Services Resident Agency (NISRA) agents.
Butler was informed of his constitutional rights, voluntarily waived them, and gave a signed statement narrating the events leading to the victim’s death, admitting to hitting the victim but denying intent to kill.

Dr. Angeles Roxas, medico-legal officer, found the cause of death to be asphyxia due to suffocation by pressure exerted on the victim's head.
No skull fractures or other severe external injuries were found, though the victim showed signs of anal intercourse post-mortem based on evidence tested at the OCGHI laboratory.

The Court of First Instance found Butler guilty beyond reasonable doubt of murder qualified by abuse of superior strength, with aggravating circumstances of treachery and scoffing at the corpse.
Sentenced Butler to death and ordered indemnity of P24,000.00 to the heirs of the victim.
Butler’s motion for new trial and reconsiderations were denied.

Butler raised procedural and evidentiary issues, including challenges to the prosecution’s witnesses, the admissibility of his confession, and the application of aggravating and mitigating circumstances.
He claimed minority status (under 18 at the time of the offense), invoking suspension of sentence under the then-applicable Child and Youth Welfare Code (P.D. 603, Art. 192).
Certified copy of birth certificate admitted into evidence on appeal to establish minority.
Progress reports from the Ministry of Social Services and Development and behavior reports from the Naval Base showed good conduct and rehabilitation efforts while detained.

Whether the trial court erred in giving full credence to the prosecution witnesses’ testimonies.
Whether the trial court erred in admitting and appreciating as evidence the accused’s extrajudicial admission (confession).
Whether the trial court erred in finding the accused guilty of murder qualified by abuse of superior strength, with aggravating circumstances of treachery and scoffing at the corpse.
Whether it was proper to appreciate abuse of superior strength and treachery simultaneously and separately.
Whether the trial court erred in accepting as evidence the medico-legal officer’s testimony that suffocation caused death.
Whether the accused was entitled to the benefits of Article 192 of P.D. 603 (Child and Youth Welfare Code) regarding suspension of sentence due to minority status before its amendment by P.D. 1179.