Title
People vs. Munoz
Case
G.R. No. L-38969-70
Decision Date
Feb 9, 1989
In 1972, mayor's bodyguards conspired to brutally murder three Bulatao family members in San Carlos City, Pangasinan. Convicted of murder with treachery, appellants received reclusion perpetua and indemnity.

Case Digest (G.R. No. L-38969-70)
Expanded Legal Reasoning Model

Facts:

  • Parties and Context
    • The respondents-appellants, Feliciano Munoz (alias "Tony"), Marvin Millora, Tomas Tayaba (alias "Tamy Tayaba"), and Jose Mislang, were charged with and convicted of three counts of murder.
    • One of the accused, Munoz, did not appeal, thereby accepting his sentence; the others appealed their convictions.
    • The prosecution sought affirmation and an increase of the penalty.
  • Incident Description
    • On June 30, 1972, in Balite Sur, San Carlos City, Pangasinan, a group of eleven armed men, mostly bodyguards of the town mayor, went out in a jeep to execute alleged cattle rustlers.
    • The group visited the house of Mauro Bulatao to inquire about his son Arsenio. Four men, including the appellants, entered the house while the rest surrounded it.
    • Millora shot Mauro Bulatao at arm's length, killing him instantly while Munoz, Tayaba, and Mislang stood by without intervention.
    • The group dragged out sixteen-year-old Aquilino Bulatao, who was kicked repeatedly in the head by Munoz before being taken along with the assailants.
    • They forced Juana Bulatao to lead them to Alejandro Bulatao, who was tending to cows with his son Pedro. Alejandro and his wife were ordered to lie down; Alejandro was then shot twice in the head by Munoz, killing him instantly.
    • As Pedro escaped under gunfire, Aquilino was kicked again by Munoz and ultimately shot to death by Munoz in the head and body.
    • Millora and Munoz collected the spent shells and fled with their companions, leaving Juana with the bodies.
  • Testimonies and Evidence
    • Key witnesses included Melecia Bulatao (Mauro's daughter), Jose Bulatao (Mauro's son), Juana Bulatao (Alejandro’s wife), and Pedro Bulatao (Alejandro’s son), whose testimonies described the killings in detail and identified the accused.
    • Medical evidence corroborated the brutality and nature of the wounds sustained by the victims, including multiple gunshot wounds and physical assault injuries.
    • The defense presented alibis and alternate versions involving exchange of gunfire and claimed that some accused were not present during the killings.
    • The trial court found defense witnesses’ testimonies unsatisfactory and unbelievable, citing inconsistencies and suspicion about their credibility.
    • The court also rejected claims that the victims were armed, noting the absence of firearms at the scene.

Issues:

  • Whether the appellants were properly convicted as accomplices or principals in the murders of the Bulatao family members.
  • Whether there was a conspiracy among the accused and their companions to commit the murders.
  • The appropriate penalty to be imposed considering the constitutional prohibition against the imposition of the death penalty.
  • The correct interpretation of Article III, Section 19(1) of the 1987 Constitution relating to the abolition or non-imposition of the death penalty and its effect on the three-period scheme of penalties under the Revised Penal Code.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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