Facts of the Case
On the morning of August 16, 1995, prosecution witnesses, including Rogelio Conato, were having breakfast at Gabriel Bulac's home, after which Reynaldo joined Jacinto and Herman at Carlos Cadayona's house, where they were drinking. An altercation arose when Jacinto struck Reynaldo with a nearly empty rum bottle, after which Herman stabbed Reynaldo twice. These fatal injuries resulted in Reynaldo's death shortly thereafter. A post-mortem examination conducted by Dr. Eva Jesus C. Arligue confirmed the nature of the wounds inflicted.
Procedural History
On October 3, 1995, Provincial Prosecutor Andres G. Yu Jr. filed an information for murder against the Bato brothers, who both pleaded not guilty at their arraignment on November 8, 1995. The Regional Trial Court conducted a trial, hearing testimony from four prosecution witnesses and the accused-appellants. On October 28, 1996, the trial court convicted both brothers of murder, sentencing them to reclusion perpetua and ordering them to pay civil indemnity and funeral expenses to Reynaldo's heirs. The Bato brothers appealed the decision.
Issues Raised
The appellate court considered four main issues: (1) existence of conspiracy between the accused; (2) whether treachery was present to qualify the killing as murder; (3) the credibility of prosecution evidence; and (4) the applicability of the mitigating circumstance of incomplete self-defense.
Court's Ruling: Conspiracy
The court found no proof of conspiracy. Although Herman made a statement indicating intent to kill, there was no evidence of a prior agreement between the brothers to kill Reynaldo. Jacob's initial attack was not fatal, nor was there a clear plan to murder Reynaldo. Instead, Jacinto's actions were deemed those of an accomplice rather than co-principal, reducing his culpability.
Court's Ruling: Treachery
The killing was characterized as murder due to the qualifying circumstance of treachery. Herman's attack was premeditated, and Reynaldo had no opportunity to defend himself as he was unexpectedly attacked while in a seemingly friendly social engagement. This combination of surprise and vulnerability fulfilled the criteria for treachery, thus affirming the trial court's determination of murder rather than homicide.
Court's Ruling: Credibility of Evidence
The appellate court found the prosecution’s evidence credible and consistent. Rogelio’s testimony indicated that there were no signs of altercation before the stabbing, reinforcing the narrative of treachery. The trial court's assessment of witness credibility, based on the firsthand observation of witness demeanor, was respected and upheld.
Court's Ruling: Self-Defense
The court rejected the claim of self-defense, which the accused-appellants asserted. The trial court determined that they did not prove that Reynaldo was the unlawful aggressor, and thus self-defense could not be invoked. Consequently, their intoxication at the time of the incident was irrelevant to their claims.
Penalty Imposed
Given the conviction of Herman as a principal in murder, the court upheld the sentence of reclusion perpetua as appropriate, devoid of aggr
...continue readingCase Background
- The case is an appeal by Herman D. Bato and Jacinto D. Bato from a decision rendered by the Regional Trial Court of Southern Leyte, Maasin.
- The trial court found the accused guilty beyond reasonable doubt of the crime of murder.
- The court sentenced them to reclusion perpetua and ordered them to pay the victim's heirs various indemnities totaling fifty-two thousand four hundred and four pesos (P52,404.00).
Incident Summary
- The incident occurred during a town fiesta on August 16, 1995, around 6:00 AM, at the residence of Gabriel Bulac in Barangay Pansil, Malitbog, Southern Leyte.
- Prosecution witness Rogelio Conato, the victim Reynaldo Sescon, and others were having breakfast before Reynaldo proceeded to Carlos Cadayona's house.
- At Cadayona's house, Reynaldo, along with Jacinto and Herman, engaged in drinking Tanduay Rum while in a jovial state.
- A sudden altercation arose when Jacinto struck Reynaldo with a Tanduay Rum bottle, followed by Herman stabbing Reynaldo in the breast after expressing intent to kill.
- Witnesses, including Rogelio and Virgilia Cadayona, testified about the events leading to Reynaldo's death, which was confirmed to be due to massive bleeding from stab wounds by Dr. Eva Jesus C. Arligue.
Charges and Trial Proceedings
- On October 3, 1995, the Provincial Prosecutor filed an information against the Bato brothers for murder, citing intent to kill, treachery, and evident premeditation.
- The accused pleaded "not guilty" during their arraignment on November 8, 1995.
- The trial featured testimonies from four prosecution witnesses and the accused-appellants themselves.
- The trial court, on October 28, 1996, convicted both brothers and sentenced them accordingly.
Issues Raised
- The appeal raised four primary issues:
- Existence of conspiracy in committing the offense.
- Whether treache