Case Summary (G.R. No. 129732)
Facts of the Case
On May 3, 1992, Rolando Buenaventura, Sr. was involved in a drinking session outside his home when a conflict arose involving the accused-appellant, Mario Basco. Tensions escalated when Basco brandished a knife, leading to attacks that eventually drew in family members of the Buenaventura family. Following a series of altercations and after some de-escalation, Basco returned to the Buenaventura household and, without provocation, shot Rolando Buenaventura, Sr. multiple times, resulting in the latter's immediate death.
Autopsy Findings
The relevant autopsy conducted post-mortem revealed multiple gunshot wounds, with the deceased suffering three distinct gunshot injuries. The detailed examination identified the entry and exit points of the bullets, indicating that the shots were fired at close range, further substantiating the assertion that the shooting was deliberate rather than accidental.
Defense Argument
The defense presented a contrasting narrative claiming that Basco did not initiate the confrontation and that the eventual shooting was a result of a struggle instigated when Rolando Buenaventura, Sr. allegedly aimed a firearm at Basco. This version attempted to invoke the concept of self-defense, asserting that the discharge of the weapon was accidental, occurring during a grappling incident.
Trial Court Decision
The trial court evaluated the testimonies and evidentiary submissions, ultimately finding Basco guilty of murder. The court highlighted that the circumstances of the shooting displayed evident treachery, as Basco attacked Rolando while the latter was unsuspecting and engaged in a domestic setting. The court emphasized that the physical evidence, including the nature of the wounds and the testimony from Rolando's family, was contradictory to Basco's defense.
Appeal Claims
Basco's appeal challenged the trial court's ruling on several grounds: the assertion of incomplete self-defense, the imposition of the penalty of reclusion perpetua, and the finding of evident premeditation in the act of killing. The accused sought to have the decision revised and the penalties adjusted.
Conclusion of the Court
The appellate court found the arguments raised in the appeal to be without merit. It concluded that the overwhelming evid
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Case Overview
- The case revolves around the murder of Rolando Buenaventura, Sr., who was shot by Mario Basco y Salao on May 3, 1992, in Tondo, Manila.
- The prosecution argued that Basco acted with intent to kill, evident premeditation, and treachery.
- The trial court sentenced Basco to reclusion perpetua and ordered him to pay damages to the heirs of the victim.
Factual Background
- On the evening of May 3, 1992, Rolando Buenaventura, Sr. was engaged in a drinking spree with friends outside his residence.
- Mario Basco, also part of the drinking group, was involved in an altercation with Emy, a cousin of the deceased, which escalated tensions.
- An incident occurred where Basco threatened Emy with a balisong, leading to a physical confrontation that was temporarily diffused by the arrival of Basco's wife.
- Later that night, Basco returned to the Buenaventura residence, where he shot Rolando Buenaventura, Sr. without provocation.
Testimony and Evidence
- Ednalyn Buenaventura, the daughter of the deceased, provided key testimony detailing the events leading up to the shooting.
- Medical evidence from the autopsy revealed multiple gunshot wounds, confirming the fatal nature of the attack