Case Summary (G.R. No. 189218)
Overview of Convictions and Appeals
The trial court convicted the four accused of murder, with only Munoz not filing an appeal, implying acceptance of his sentence. The remaining appellants—Millora, Tayaba, and Mislang—challenged their convictions, asserting their innocence. The prosecution, however, aimed to uphold the convictions, even advocating for increased penalties.
Facts Leading to the Murders
The prosecution's evidence presented a gravely disturbing sequence of events wherein the accused, along with several unidentified accomplices, approached the Bulatao residence under the pretense of seeking Mauro Bulatao’s son, Arsenio. Once inside the home, Millsora shot Mauro at close range, killing him instantly. In the course of the attacks, Aquilino, the sixteen-year-old son of Mauro, was brutally assaulted and later executed. The violence escalated at Alejandro's residence, where he was shot while lying down, despite the desperate pleas from his son, Pedro. Witness testimonies from family members corroborated the brutality of these actions, which occurred without any provocation.
Witness Testimonies and Credibility Concerns
Key testimonies were provided by family members of the victims, including Melecia and Jose Bulatao, and Juana Bulatao, Alejandro's wife. Despite some inconsistencies in their accounts, the trial court found their testimonies credible, attributable to fear of retaliation post-tragedy. The defense attempted to undermine their credibility by emphasizing the delay in reporting the incidents, but the court noted that fear likely prevented witnesses from speaking out sooner.
Forensic Evidence and Defenses Presented
The autopsy reports confirmed the nature and severity of the victims’ injuries, substantiating claims of homicide rather than any alleged exchange of gunfire as suggested by the appellants’ defense. The appeals presented individual defenses, primarily alibi, which the trial court found unconvincing due to lack of corroborative evidence and the implausibility of the defendants' assertions.
The Court’s Assessment of Intent and Conspiracy
The court affirmed that the actions of all accused constituted a conspiracy to commit murder, rendering each liable as co-principals in the crimes. The evidence indicated a premeditated decision among the accused to pursue and execute the Bulatao family, characterized as a collective and deliberate act of violence.
Legal Analysis of the Murder Charges
Each killing was classified as murder under Article 248 of the Revised Penal Code, occurring with treachery as the victims were defenseless at the time of the attacks. The constitutionality of the death penalty’s abolition under the 1987 Constitution delineated the applicable penalties, leading the court to impose reclusion
...continue readingCase Syllabus (G.R. No. 189218)
Case Overview
- The case involves the conviction of four individuals for the murder of three victims, the Bulatao family.
- Three of the convicted individuals—Marvin Millora, Tomas Tayaba, and Jose Mislang—have appealed their convictions, insisting on their innocence, while Feliciano Munoz, who did not appeal, has accepted his sentence.
- The prosecution presents a narrative of a brutal execution carried out by a group of armed individuals, including the accused, against innocent farmers.
Incident Details
- The events occurred on June 30, 1972, in Balite Sur, San Carlos City, Pangasinan.
- The accused, armed and organized, sought out Mauro Bulatao, who was shot at close range by Millora as he approached his house.
- Following Mauro's death, the group brutally assaulted his son, Aquilino, before subsequently murdering Alejandro Bulatao in front of his family.
- The prosecution's evidence includes harrowing testimonies from family members and corroborating medical reports detailing the nature of the injuries sustained by the victims.
Witness Testimony
- Key witnesses include Melecia Bulatao, Jose Bulatao, Juana Bulatao, and Pedro Bulatao, who provided direct accounts of the killings.
- Testimonies highlighted the brutality of the attacks, including Millora shooting Mauro and Munoz kicking Aquilino before ultimately killing him.
- Aspects of witness credibility were challenged, particularly regarding delays in reporting the crimes and inconsistencies in test