G.R. No. 249859 - People vs. Mark Anthony Yulo y Gallo a.k.a. "Tata" and Mark Ryan Bueno y Corona a.k.a. "Nonoy"

Case Digest (G.R. No. 249859)
Expanded Legal Reasoning Model

Facts:

Overview of the Incident

On the evening of January 2, 2005, Felix Sabasan y Magango was fatally stabbed outside his residence in Sitio Culasisi, Brgy. San Luis, Antipolo City.
The victim sustained multiple stab wounds on his front, back, nape, and neck, with the injuries to the nape, neck, and trunk deemed fatal.

Identification and Arrest of the Accused

Two men, Mark Anthony Yulo y Gallo (a.k.a. "Tata") and Mark Ryan Bueno y Corona (a.k.a. "Nonoy"), were identified as the suspects.
During a search conducted shortly after their apprehension (early hours of January 3, 2005), a blood-stained ice pick was recovered from Yulo’s possession.
An Information for murder was filed on January 6, 2005, charging the accused with stabbing Felix with a bladed weapon, in furtherance of a conspiracy with an unidentified accomplice.

Pre-Trial and Evidence Presentation

Upon arraignment, Yulo and Bueno pleaded “not guilty.”
During pre-trial, parties stipulated on matters such as jurisdiction, the identities of the accused, and the details surrounding the incident.
The trial proceeded with the prosecution presenting four key witnesses:

Lucena Abayon – Provided an eyewitness account of hearing a shout ("Pa!") and witnessing the chase, stating that she saw three men (two of whom were later identified as Yulo and Bueno) chasing Felix. She testified that when the suspects caught up with Felix, Bueno and another man restrained him while Yulo stabbed him.
Nehemias Sabasan – Recounted hearing Felix’s shouts and, upon seeking his father’s identity of the assailants, reported that Felix named “Tata” and “Nonoy.”
Cristy Cardinal – Asserted that Yulo visited her residence around 11:00 p.m. asking for a glass of water and subsequently admitted to stabbing Felix, although she later dismissed his claim.
Police Chief Inspector Jose Arnel Marquez – Provided the medico-legal opinion that the fatal wounds were inflicted by a sharp, pointed weapon, noting that more than one such instrument might have been used.

Testimonies and Corroborative Evidence

Abayon’s Testimony

Detailed her observation from within her own house, noting the illumination provided by nearby street lamps which enabled her to see the sequence of events.
Confirmed that Felix was chased by three men and, as he stumbled outside his house, was overtaken by the accused which led to the stabbing.

Nehemias’s Account

Noted that he was at home when he heard the commotion and upon stepping out, saw his son injured and bleeding.
Reported that Felix, while being transported to the hospital, identified his attackers without hesitation.

Cardinal’s and Other Documentary Evidence

Cardinal’s testimony of an alleged admission by Yulo bolstered the prosecution’s case, despite defense arguments about her credibility.
The recovered blood-stained ice pick and the consistency of the eyewitness accounts provided substantial corroboration of the accused’s involvement.

Judicial Proceedings and Subsequent Appeals

Regional Trial Court (RTC) Decision (November 14, 2016)

The RTC found both accused guilty beyond reasonable doubt of murder, under Article 248 of the Revised Penal Code, citing the testimonies of Abayon and Cardinal and the dying declaration made by Felix.
The RTC sentenced both accused to reclusion perpetua and ordered them to pay various damages (moral, civil indemnity, exemplary, actual, and loss of earning capacity) to the heirs of the victim.

Court of Appeals (CA) Decision (March 4, 2019)

The CA upheld the RTC’s conviction, finding that the evidence established the accused’s guilt, particularly noting the corroborative dying declaration and the clear eyewitness identifications.
While the CA concurred with the finding of guilt, it modified the award of damages by increasing some amounts pursuant to established precedents.

Issue on Appeal

The accused-appellants filed their Notice of Appeal, arguing that the evidence—specifically the testimonies of Abayon and Cardinal—was riddled with inconsistencies and that the qualifying circumstances of treachery and abuse of superior strength were improperly applied.

Issues:

Sufficiency of Prosecution’s Evidence

Whether the eyewitness testimonies, particularly those of Abayon and Cardinal, were credible and sufficient to establish the guilt of the accused beyond reasonable doubt.
Whether Felix’s statement, made during the critical moments before his death, should be admitted as a dying declaration or merely as res gestae.

Establishment of Qualifying Circumstances

Whether the qualifying circumstance of treachery was applicable given the sequence of events, including the victim’s ability to initially escape.
Whether abuse of superior strength was properly demonstrated by the coordinated attack on the victim.

Liability of Co-Accused in the Context of Conspiracy

Whether holding Bueno equally liable as a principal, despite his participation being limited to restraining the victim, is warranted under the doctrine that in a conspiracy the act of one is the act of all.

Appropriateness of Penalty and Damage Awards

Whether the imposition of reclusion perpetua, without the death penalty, was compatible with the established circumstances of the crime.
Whether the adjustments made by the CA in awarding damages (moral, civil indemnity, and exemplary) were properly supported in view of the penalty imposed.

Ruling:

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Ratio:

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Doctrine:

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Case Digest (G.R. No. 249859) Core Legal Reasoning Model Expanded

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Case Digest (G.R. No. 249859) Expanded Legal Reasoning Model

Facts:

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Doctrine:

Case Digest (G.R. No. 249859)
Core Legal Reasoning Model

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Case Digest (G.R. No. 249859)
Expanded Legal Reasoning Model