Case Summary (G.R. No. 93851)

Unexplained Delay in Dying Declaration

• The Court disregarded the dying declaration of the deceased Buenaventura Mendoza in a similar case due to the widow's failure to disclose it to police investigators and a barangay councilman until trial.
• The widow's explanation for the delay was deemed insufficient, leading to skepticism about the credibility of the dying declaration.

Credibility Issues in the Current Case

• Bernadette Estepa's excuse for not revealing her brother Bong Estepa's dying declaration was fear due to being alone while her family was abroad.
• The Court questioned why she did not report the incident to authorities after her family returned, suggesting that their presence could have provided her with the necessary support.
• The inconsistency between Bong Estepa's statement of being "shot and stabbed" and the autopsy findings, which indicated he died from a single gunshot wound, further undermined the prosecution's case.

Trial Court's Findings and Appeals

• The Regional Trial Court found both Mark Bayquen and Wilfredo Boco guilty of homicide, sentencing them to imprisonment and ordering them to pay damages to the victim's heirs.
• Boco appealed, arguing that the trial court erred in crediting Bernadette Estepa's testimony and in admitting the deceased's declaration.
• Bayquen also appealed, raising similar issues regarding the credibility of Bernadette's testimony and the lack of motive for the accused.

Court of Appeals Decision

• The Court of Appeals affirmed the trial court's decision, leading to Boco's motion for reconsideration, which was denied.
• Bayquen filed a petition, claiming the appellate court failed to consider specific legal provisions and evidence.

Sequence of Events Leading to the Incident

• On July 23, 1984, Teofilo Estepa returned home and dined with his sister Bernadette, expressing concern about being sought by others.
• The following day, after a series of events, Teofilo was shot, and Bernadette discovered him bleeding and heard him name his assailants.

Testimony and Evidence Presented

• Bernadette Estepa testified that her brother identified Mark Bayquen and Wilfredo Boco as his attackers before he died.
• However, her statements made shortly after the incident did not name any assailants, raising questions about her credibility.

Analysis of Dying Declaration and Res Gestae

• The Court emphasized the importance of spontaneous statements made immediately after the incident, which should be given more weight than later declarations.
• The autopsy findings confirmed that Teofilo Estepa died from a gunshot wound, contradicting the claim of being stabbed.

Lack of Motive and Credibility of Accusations

• The prosecution&...continue reading

Case Syllabus (G.R. No. 93851)

Case Background

• The case revolves around the charges of homicide against Mark Bayquen and Wilfredo Boco.
• The accusations stemmed from an incident on July 25, 1984, in Baguio City, where Teofilo Estepa was attacked and killed.
• The charges were based on the alleged conspiracy and premeditated assault by the accused, armed with a gun and a bladed weapon.

Charges and Trial Proceedings

• The information filed by Assistant City Fiscal Jose P. Basco specifically cited the details of the attack, resulting in Estepa's death due to multiple injuries.
• Both accused pleaded not guilty during their arraignment.
• The trial court rendered its decision on December 15, 1989, finding both Bayquen and Boco guilty of homicide instead of murder, sentencing them to imprisonment and ordering them to indemnify the victim's heirs.

Errors Assigned on Appeal

• Boco's appeal included errors related to the credibility of witness Bernadette Estepa and the admission of dying declarations.
• Bayquen raised concerns over the trial court's treatment of Bernadette's statements and the exclusion of defense testimonies.
• Both accused questioned the sufficiency of evidence and the credibility of the prosecution's case.

Court of Appeals Decision

• On May 31, 1990, the Court of Appeals affirmed the trial court...continue reading