Case Summary (G.R. No. 139530)
Procedural History
The trial court issued its decision on January 26, 1999, finding the appellant guilty of murder, as defined under Article 248 of the Revised Penal Code. As a result, Bautista was sentenced to reclusion perpetua and ordered to pay the heirs of the victim both actual expenses amounting to P32,397.00 and a mandatory civil indemnity of P50,000.00.
Facts of the Case
On the night of the incident, the appellant and the deceased were among a group having a drinking spree. Following the departure of their companions, an altercation arose. Witness Lorenzo Dumase observed the appellant pursuing the deceased. Hilario, who later encountered the appellant and Danilo, the appellant's brother, noted that Bautista had a blood-stained shirt and admitted to killing Bacoling. Furthermore, upon confessing to another companion, Buyagan, the appellant indicated his guilt, which led to police involvement. An autopsy performed on Bacoling revealed multiple wounds as the cause of death.
Arguments Presented
The appellant claimed self-defense, asserting that he had been provoked. He recounted that prior to the killing, Bacoling had insulted him, leading to a confrontation that resulted in his using Bacoling's bolo against him. The trial court ultimately concluded that evidence presented established guilt beyond reasonable doubt.
Court's Findings on Murder vs. Homicide
The trial court categorized the crime as murder based on the presence of treachery, which, under Article 14 of the Revised Penal Code, requires specific circumstances. The court determined that the appellant took advantage of the deceased's vulnerable position, as the latter was running away and caught off guard when attacked from behind.
Analysis of Treachery
The court highlighted that treachery, as defined in jurisprudence, necessitates a method of execution that prevents the victim from defending themselves. Ultimately, the court found sufficient evidence to affirm that treachery was involved, distinguishing this case from precedents where the victim had a chance to evade or defend themselves.
Consideration of Mitigating Circumstances
In addressing the appellant's claim for mitigating circumstances such as drunkenness, provocation, and unlawful aggression, the court found insufficient evidence to substantiate these claims. While it was established that Bautista and his companions had been drinking, it was not demonstrated that his intoxication impaired his capaci
...continue readingCase Syllabus (G.R. No. 139530)
Overview of the Case
- The case involves an appeal by Pepe Bautista y Sabado against the January 26, 1999 Decision of the Regional Trial Court of Nueva Vizcaya, Branch 30.
- The trial court found Bautista guilty of murder in Criminal Case No. 613 and sentenced him to reclusion perpetua.
- The charge was based on events occurring on February 3, 1993, in Barangay Balance, Dupax del Norte, Nueva Vizcaya.
Details of the Charge
- The Information filed on April 13, 1993, stated that Bautista, with intent to kill and qualified by treachery and evident premeditation, assaulted Rodolfo Bacoling using a bolo, which resulted in Bacoling's death.
- The prosecution cited the aggravating circumstance of nighttime, allegedly sought by Bautista to ensure impunity.
Sequence of Events
- On the night of February 3, 1993, Bautista and Bacoling engaged in a drinking spree with several others at the house of Fausto Polon.
- After the others left, Bautista and Bacoling remained, and around 9 p.m., a neighbor observed Bautista chasing Bacoling.
- Around midnight, Bautista and his brother Danilo confessed to another acquaintance, Hilario, that Bautista had killed Bacoling and showed him a blood-stained shirt and bolo.
- At 6 a.m. on February 4, Bautista confessed to another companion, Buyagan, leading Buyagan to report the incident to authorities.
- An autopsy conducted on February 5 revealed that Bacoling died from multiple hacking wounds causing hemorrhagic shock.