Facts:

The case of People of the Philippines vs. Feliciano Munoz, et al. (G.R. Nos. L-38968-70) revolves around the brutal murders of three members of the Bulatao family, occurring on the morning of June 30, 1972, in Balite Sur, San Carlos City, Pangasinan. The victims were Mauro Bulatao, his 16-year-old son Aquilino, and Alejandro Bulatao, with evidence suggesting that each was shot execution-style by a group of eleven armed individuals, including defendants Marvin Millora, Tomas Tayaba, and Jose Mislang, also known as "Tamy Tayaba." The prosecution established through witness testimonies that these individuals, along with Feliciano Munoz and the other unapprehended accomplices, had conspired to seek out and punish the Bulataos, whom they accused without evidence of being cattle rustlers. Shortly after arriving at Mauro's residence and confronting him, Millora shot him in the mouth, leading to his immediate death. The group then violently assaulted Aquilino before procee

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Facts:

Chronology and Participants

• On the morning of June 30, 1972, in Balite Sur, San Carlos City, Pangasinan, a planned execution was carried out by a group of eleven armed men.
• The group, which included bodyguards of the town mayor, comprised Feliciano Munoz, Marvin Millora, Tomas Tayaba, Jose Mislang, and seven other unidentified men.
• The accused had previously set out to locate the son of Mauro Bulatao at the house of Mauro Bulatao after asking for the address of Mauro’s son, Arsenio.

Events of the Crime

• The group approached the house of Mauro Bulatao, with four men (including Munoz, Millora, Tayaba, and Mislang) entering the premises while the others took up strategic positions outside.
• Once inside:
• Mauro Bulatao was encountered by Millora, who shot him at arm’s length, hitting him in the mouth so that he died instantly as his dying moments were witnessed by his family.
• Immediately after, the accused dragged out Mauro’s 16-year-old son, Aquilino. As Aquilino lay helpless on the ground, Munoz kicked him several times in the head while the others stood by. Eventually, Aquilino was also shot to death by Munoz.
• The perpetrators then forced Juana Bulatao, Alejandro Bulatao’s wife, to lead them to her husband:
• At Alejandro Bulatao’s residence, the group encountered him tending to their cows with his young son, Pedro.
• Despite Pedro’s desperate pleas, Munoz ordered both Alejandro and his wife to lie down, and proceeded to shoot Alejandro twice in the head, killing him instantly.
• Later, Aquilino’s further brutal treatment was noted as the group targeted him by both kicking and ultimately shooting him.

Witness Testimonies and Evidence

• Eyewitnesses—including Mauro’s daughter Melecia, Mauro’s son Jose, Juana Bulatao, and Pedro Bulatao—provided detailed accounts that described the sequence and brutality of the shootings and beatings.
• The judicial record emphasized the consistency and straightforwardness of testimony, notably that of Jose Bulatao who clearly identified Millora as the shooter and described the inaction of the others while the crimes unfolded.
• Medical evidence presented by Dr. Juanito de Vera, based on autopsy reports, corroborated the physical injuries of the victims:
• Mauro Bulatao’s gunshot wounds (entrance at the upper lip with an exit at the back of the head, and a wound at the lower lip).
• Alejandro Bulatao’s lacerated gunshot wounds to his face and head with significant tissue damage.
• Aquilino Bulatao’s entrance and exit wounds on his head and additional wound on his shoulder.

Defenses and Conspiratorial Nature

• Each of the accused (except Munoz, whose conviction had become final due to non-appeal) pleaded innocence by invoking individual defenses and alibi claims.
• Testimonies by defense witnesses attempted to portray the events as a shoot-out between two groups, suggesting that the Bulataos were criminals engaged in an exchange of gunfire.
• The trial court rejected these defenses, noting that the evidence clearly supported a premeditated conspiracy wherein all participants cooperated in the execution of the crime.
• The court observed that the common plan was evident from the initial gathering of the group and their strategic coordination during the killing, supporting the notion that “the act of one is the act of all.”

Status of Proceedings and Sentencing

• Out of the group of eleven charged with murder, only four were tried while the other seven remained unidentified and untried.
• Feliciano Munoz did not appeal and his sentence had become final and executory.
• The appeals of Marvin Millora, Tomas Tayaba, and Jose Mislang were the focal point of the appellate review regarding both their guilt and the proper computation of the penalty.

Issue:

Determination of Guilt and Degree of Participation

• Whether the evidence showing that all accused acted in concert under a common design to kill the Bulataos justifies holding each as a co-principal in the murders.
• Whether the trial court erred in differentiating the degree of participation among the accused by assigning one as principal and the others as mere accomplices.

Credibility and Weight of Testimony

• Whether the delay in the witnesses’ denunciation (which the appellants argued should impugn their credibility) was justified given the fear of reprisal by humble, local barrio folk.
• The evaluation of conflicting testimonies—especially the inconsistencies pointed out by defense witnesses—and the reliability of the eyewitness accounts corroborated by medical evidence.

Interpretation and Application of Constitutional Provisions

• How Section 19(1), Article III of the 1987 Constitution, which prohibits the imposition of the death penalty, should affect the penalty for murder under Article 248 of the Revised Penal Code.
• Whether the abolition of the death penalty necessarily mandates a reconfiguration (i.e. the division into three periods) of the penalties for murder, or if only the maximum period should be modified by substituting reclusion perpetua for death.

Legislative vs. Judicial Roles in Penalty Adjudication

• The extent to which the courts may interpret or modify penalty ranges versus the powers reserved to Congress to prescribe and adjust such penalties.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)