Case Summary (G.R. No. 131512)
Facts of the Case
The prosecution's narrative describes the incident as a concerted attack by the accused, where they allegedly conspired to assault Yarza with intent to kill, using personal violence and the advantage of their superior strength. The charge was formalized through an information dated February 28, 1990, leading to Bautista's arrest on March 26, 1990, after which he pleaded not guilty during arraignment.
Trial and Judgment
The Regional Trial Court, Manila, convicted Renato Bautista on June 1, 1993, finding him guilty beyond reasonable doubt of murder, sentencing him to reclusion perpetua, and ordering him to indemnify the victim's heirs. The trial court considered the aggravating circumstance of abuse of superior strength but noted mitigating factors such as provocation.
Prosecution's Evidence
Witness testimonies indicated that Rodel Yarza, after playing cards in his neighborhood, was assaulted and severely stabbed. Zenaida Yarza, the victim's wife, testified that her husband identified Bautista as the assailant before succumbing to his injuries. This declaration was deemed a dying declaration and submitted as crucial evidence by the prosecution.
Defense's Arguments
Bautista's defense contended that he did not participate in the stabbing and claimed that he returned home after being struck first by Yarza. They argued that the dying declaration lacked admissibility because it was not made under the consciousness of impending death. The defense also pointed out that the time between the initial altercation and the fatal attack did not allow for premeditation.
Court's Analysis on Dying Declaration
The court found that the criteria for a dying declaration were met. Despite the defense's argument, it recognized that Yarza's condition indicated a realization of his impending death, which warranted the admissibility of his last words identifying Bautista as his attacker. This corroborated the prosecution's narrative of events leading to the murder.
Conclusion and Verdict
The Supreme Court upheld the lower court's ruling, affirming Bautista's conviction for murder. The appeal was dismissed, re
...continue readingCase Syllabus (G.R. No. 131512)
Case Background
- The case concerns the crime of murder, where accused-appellant Renato Bautista was charged along with co-accused Arman Hernandez, Arnold Mendoza, and Jess Sabarin.
- The Information was filed on February 28, 1990, detailing the murder of Rodel Yarza Y Lopez, who was attacked and stabbed on December 14, 1989, in Manila.
- The prosecution alleged that the accused conspired and used their superior strength to commit the crime, resulting in Yarza's death from a mortal stab wound.
Trial Proceedings
- The trial commenced after the arrest of Renato Bautista, while his co-accused remained at large.
- Bautista pleaded "Not Guilty" during his arraignment, leading to a trial solely against him.
- On June 1, 1993, the trial court convicted Bautista of murder, sentencing him to reclusion perpetua and ordering him to indemnify the victim's heirs.
Key Arguments and Evidence
- The trial court considered the aggravating circumstance of abuse of superior strength and found evident premeditation, which was