Case Summary (G.R. No. 232649)
Background of the Case
An Information was filed against Bulutano and Serad for the crime of murder under Article 248 of the Revised Penal Code, alleging that both were involved in striking Wilbert Augustus with wooden clubs with intent to kill. After trial proceedings, the Regional Trial Court (RTC) found Bulutano guilty of murder resulting in an appeal to the Court of Appeals (CA), which upheld the RTC's decision. Bulutano then sought further review from the Supreme Court.
Ruling of the RTC
In its judgment dated July 11, 2013, the RTC convicted Bulutano of murder, highlighting the positive identifications made by prosecution witnesses and determining that there existed treachery during the commission of the crime. The RTC sentenced Bulutano to reclusion perpetua and ordered him to pay various damages to the victim's heirs.
Ruling of the CA
The CA affirmed the RTC's ruling in its decision dated May 23, 2016. It upheld the findings regarding Bulutano’s guilt and the presence of treachery. The CA noted that the alleged inconsistencies in the testimonies of the witnesses were minor and did not detract from their credibility.
Issues Raised on Appeal
Bulutano's appeal raised two primary issues:
- Whether the CA erred in convicting him without proof of guilt beyond reasonable doubt.
- Whether the CA erred in appreciating the circumstance of treachery in the killing.
Supreme Court's Ruling on the First Issue
The Supreme Court confirmed the lower courts' conviction of Bulutano. It addressed Bulutano's argument concerning inconsistencies in witness testimonies, stating that such inconsistencies were trivial and did not undermine the overall credibility of the witnesses or their testimonies, which clearly identified Bulutano as having participated in the attack.
Supreme Court's Ruling on the Second Issue
The Court found in favor of Bulutano regarding the presence of treachery. It reasoned that for treachery to be established, it must be shown that the aggressor deliberately adopted a method of attack that ensured the success of the crime without risk to themselves. The circumstances indicated that the attack was impulsive and lacking in forethought, as noted witness testimonies suggested that the victim was merely passing by when he was assaulted.
Modification of the Crime Classification and Sentencing
With the removal of the qualifying circumstance of treachery, the Supreme Court ruled that the crime should be classified as homicide rather than murder. It impo
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Case Overview
- This case involves an ordinary appeal filed by Mario Bulutano y Alvarez (Bulutano), who contests the Decision of the Court of Appeals (CA) affirming his conviction for murder by the Regional Trial Court (RTC) of Makati City.
- The RTC found Bulutano guilty beyond reasonable doubt of murdering Wilbert Augusto (Wilbert) on February 16, 1998.
Factual Background
- An Information was filed against Bulutano and Jhun Serad for the murder of Wilbert.
- The prosecution claimed that both accused, armed with wooden clubs, conspired with others to kill Wilbert with evident premeditation and treachery.
- The incident occurred on February 16, 1998, in Makati City, stemming from a brawl between two groups.
Prosecution's Version
- Several witnesses, including Reynaldo Astrolavio and Allan Ramos, observed the attack on Wilbert.
- Reynaldo saw Serad strike Wilbert on the head and later witnessed Bulutano continue the assault while Wilbert was on the ground.
- Allan noted that Bulutano and Serad arrived with weapons and attacked Wilbert, despite him being defenseless.
- Gerald Manaog corroborated the witnesses' accounts, stating Bulutano also struck Wilbert after he had fallen.
Defense's Version
- Bulutano denied involvement, claiming he was merely a bystander and that Serad was the sole perpetrator.
- He described a sequence of events where he was out with friends and was only trying to help another individual involved in a separate fight.
- Bulutano suggested that the prosecution witnesses were motivated by a basketball rivalry rather than any genuine animosity towar