G.R. No. 217024 - People vs. Bolo y Maldo

The case involves three accused: Marcelo Paat (alias Pedring), Virgilio Paat, and Juan Donato.
All three were charged with murder for the killing of Teodorico Catuiran.
At trial, the lower court acquitted Virgilio Paat and Juan Donato on grounds of reasonable doubt, while convicting Marcelo Paat.
The sentence imposed on Marcelo Paat considered a mitigating circumstance of passion or obfuscation, resulting in an indeterminate penalty of not less than 10 years and 1 day of prision mayor to 17 years, 4 months and 1 day of reclusion temporal, along with accessory penalties and indemnity to the heirs of the deceased.

The events transpired on the morning of August 25, 1957, in the marketplace of the barrio of Masical in the municipality of Amulong, Cagayan.
The marketplace was also frequented by the Catuiran brothers—Ricardo, Eulogio, and Teodorico—who were present for various purposes:

An altercation was sparked when Eulogio invited Juan Donato to drink basi, which led to:

Juan Donato declining the offer.
Eulogio reacting with a remark suggesting that Juan Donato was resentful.
This dismissal created tension that eventually involved Virgilio Paat and Teodorico Catuiran.

At this juncture, Marcelo Paat approached from behind and stabbed Teodorico in the back with a small bolo (imuca).
Following the stabbing by Marcelo, the following occurred:

Juan Donato and Virgilio released their hold on Teodorico.
Teodorico, still conscious, drew his bolo and struck Virgilio in the abdomen.
Teodorico staggered a few steps before collapsing and subsequently dying due to hemorrhage and shock, as confirmed by the post-mortem examination.

According to the testimony of Dr. Dulce Donato Baculi, the precise nature of Teodorico’s wounds was noted:

A stab wound above the superior angle of the right scapula.
The wound was horizontal, penetrating the upper lobe of the right lung approximately 5-1/2 inches deep and 1 inch wide.

Evidence presented by the defense showed a separate encounter earlier in the day:

It was suggested that Virgilio and Marcelo were in the marketplace searching for labor for palay transplantation in their land in Bayabat.
An incident where Virgilio, having reluctantly consumed basi after being pressed by Eulogio Catuiran, exchanged heated words with him.
During that altercation, Virgilio struck Eulogio’s forehead, which set off a chain of violent events culminating in the stabbing incidents.

While buying merchandise, he heard a scream and witnessed the moment Juan Donato and Virgilio were holding Teodorico.
He observed Marcelo Paat, coming from behind, stab Teodorico.
He noted the immediate reaction where Juan Donato and Virgilio released their hold and fled the scene.
He also recounted how Teodorico, after being stabbed, managed to stab Virgilio as he passed by.

The defense argued that Marcelo Paat’s action was committed in defense of his brother Virgilio after witnessing Virgilio being attacked.
They raised the mitigating circumstance of passion or obfuscation to justify the act.
However, the evidence indicated that:

Marcelo Paat’s attack occurred while Teodorico was already rendered helpless by the hold of Juan Donato and Virgilio.
The stabbing of Teodorico by Marcelo happened before Teodorico’s subsequent attack on Virgilio.
Thus, the claim of acting in defense lacked evidentiary support regarding immediate threat.

Whether Marcelo Paat intentionally inflicted the fatal stab wound on Teodorico Catuiran or acted in immediate defense of his brother Virgilio.

The central inquiry is if the killing was executed as an act of self-defense.
Whether the mitigating circumstance of passion or obfuscation was appropriately applied in light of the sequence and dynamics of the altercation.
The evaluation of the witness testimony, particularly the observations of prosecution witnesses, in establishing the exact order of events.