Case Digest (G.R. No. 39085) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippine Islands v. Antonio Yabut (G.R. No. 39085, September 27, 1933), the respondent, the People of the Philippine Islands, charged appellant Antonio Yabut before the Court of First Instance of Manila with murder under Article 248 of the Revised Penal Code. On August 1, 1932, inside Bilibid Prison’s Brigade 8-A in the City of Manila, Yabut—then serving sentences for two prior homicides and one serious physical injury conviction—suddenly struck fellow inmate Sabas Aseo from behind on the neck and head with a wooden club, fracturing Aseo’s skull and causing subdural and cerebral hemorrhages that led to death twenty-four hours later. Four eyewitnesses, including Chief Squad Leader José Villafuerte, testified that Yabut inflicted the blows while Aseo’s back was turned. Yabut denied responsibility, asserting Villafuerte dealt the fatal blow. The lower court rejected Yabut’s version, found all qualifying circumstances for murder established (including alevosia), a Case Digest (G.R. No. 39085) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- The appellant, Antonio Yabut, was serving a prison sentence in Bilibid Prison, Manila, for a prior conviction of homicide, having two prior final convictions for homicide and one for serious physical injuries.
- On August 1, 1932, he was charged by information with murder of fellow prisoner Sabas Aseo (“Asayo”) committed in the same prison.
- Commission of the Offense
- At about 7:30–8:00 PM in Brigade 8-A of Bilibid Prison, under the control of chief squad leader Jose Villafuerte and assistant Vicente Santos, tensions arose among prisoners Apolonio Saulo, Isaias Carreon and others.
- While Villafuerte intervened in a dispute between Carreon and Saulo, Yabut took a wooden club (Exhibit C) and struck the unarmed Sabas Aseo suddenly from behind—first on the nape and then again on the head—causing a skull fracture and subdural hemorrhage. Aseo died about 24 hours later.
- Villafuerte disarmed Yabut after a brief struggle; Yabut fled and hid in a prison latrine but was immediately apprehended by prisoner-sergeant Proceso Carangdang.
- Trial and Evidence
- In the Court of First Instance of Manila, Yabut pleaded not guilty. The trial court accepted eyewitness testimony of four prisoners and expert medical testimony (Dr. Santiago Estrada and Dr. Pablo Anzures) establishing causation of death by the blows inflicted by Yabut.
- The court rejected Yabut’s claim that Villafuerte, not he, delivered the fatal blow. It found Yabut to be a recidivist and applied Article 160 of the Revised Penal Code, convicting him of murder with the death penalty.
- Yabut appealed, assigning errors in the application of Article 160, in the court’s evaluation of defense evidence, in recognition of treachery (alevosía) as a qualifying circumstance, and in the sufficiency of proof of murder beyond reasonable doubt.
Issues:
- Whether Article 160 of the Revised Penal Code applies when the new felony (murder) is of the same character as the offense for which the convict is serving sentence (homicide).
- Whether the trial court erred in deeming the defense evidence contradictory and uncorroborated.
- Whether the qualifying circumstance of treachery (alevosía) was sufficiently established.
- Whether the evidence proves murder beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)