G.R. No. 110 - People vs Yacat

On July 6, 1900, at approximately 11 a.m., an armed conflict erupted in a locale called Guyonguyong near the town of Cabiao.
The confrontation involved two distinct groups: on one side were the Bautistas—Marcos Bautista and his 20-year-old son, Gregorio Bautista; on the other side were a group composed of Antonio Yacat, Eugenio Yacat, Cristino Yacat, Macario Mangilit, and Pedro Lising.
The reasons for the outbreak of hostilities are not clearly established in the record.

During the violent encounter, Marcos Bautista received a total of eight wounds, some of which were severe enough to be deemed mortal, resulting in his death on the scene.
In addition to Marcos, Gregorio Bautista, along with Macario Mangilit and Cristino Yacat, sustained wounds of varying seriousness.
The evidence strongly indicates that all five adversaries actively inflicted violence upon Marcos, though it remains indeterminate exactly who delivered the fatal wounds.

Although the fiscal’s information charged the incident as murder, the circumstances reveal that the fatality occurred amid a confused and tumultuous affray, thereby constituting the crime of homicide under Article 405 of the Penal Code.
No qualifying circumstances, as required for murder under Article 403 of the Code, were established in the context of the incident.

The four defendants (Antonio Yacat, Eugenio Yacat, Cristino Yacat, and Macario Mangilit) who were apprehended pleaded not guilty, yet their testimonies were self-contradictory, suggesting collective involvement with the absentee, Pedro Lising.
Gregorio Bautista, the surviving member of the Bautista faction, was unable to identify which of the adversaries inflicted the fatal wounds upon his father.
Due to the nature of the altercation and the evidence presented, it was established that each of the five assailants inflicted some degree of violence, reinforcing the collective culpability in the homicide.

Eduardo Llanera was mentioned in the record but was acquitted for lack of evidence showing active involvement as an accessory to the homicide.
Pedro Ureta, the local president of Cabiao at the time, was implicated for abusing his public office by neglecting to prosecute the crime and thereby facilitating the escape of one of the defendants (Pedro Lising).
His inaction led to the determination that he should be penalized with subsidiary imprisonment and liable for the corresponding indemnification payment should the primary offenders prove insolvent.

The defense raised a motion to dismiss the case on the grounds that the defendants should benefit from the amnesty proclamation of July 4, 1902, arguing that they had no involvement in any insurrection and that the homicide did not stem from political dissension or hatred.
The court, however, found insufficient evidentiary support for these claims, thereby rejecting the motion to dismiss on the basis of amnesty.

Whether the fatal incident should be classified as murder or as homicide committed in a confused and tumultuous affray.
The implications of the absence of clear qualifying circumstances for murder under Article 403 of the Penal Code.

Whether any one defendant can be solely identified as the killer given that each participant inflicted violence during the fray.
The extent to which the collective participation of the assailants imposes joint criminal responsibility under Article 405.

Whether Antonio Yacat’s relationship to the deceased—being his brother-in-law—constitutes an aggravating circumstance enhancing his culpability.
How such aggravating factors should influence the sentencing of the individual defendants.

Whether Pedro Ureta, by failing to prosecute and investigate the homicide, should be held criminally liable for his neglect of duty.
The appropriate penalty considering his abuse of public office.

Whether the defendants are eligible for the benefits of the amnesty proclamation of July 4, 1902, especially given the political context (or lack thereof) of the homicide.
The evidentiary standards required to substantiate claims for amnesty in connection with crimes of this nature.