Case Summary (G.R. No. 123294)
Factual Background and Incident Description
Eleven armed men, mostly bodyguards of the town mayor, sought to punish alleged cattle rustlers, targeting the Bulatao family homes. Four accused, including Millora, Munoz, Tayaba, and Mislang, entered the house of Mauro Bulatao, while the others surrounded it. Millora shot Mauro at close range, killing him instantly. The group forcibly removed Aquilino, who was brutally kicked by Munoz and later shot dead. The accused then coerced Juana Bulatao, Alejandro’s wife, to lead them to her husband, who was shot twice in the head and killed. The three victims were defenseless, their killings deliberate and executed with extreme cruelty and a lack of any legal process.
Trial Testimony and Evidence
The prosecution's witnesses included members of the Bulatao family—Melecia and Jose Bulatao, Juana Bulatao, and her son Pedro—whose testimony was consistent and credible, describing the shocking brutality of the killings and identifying the accused as principals. The testimony was supported by the autopsy report by Dr. Juanito de Vera, documenting gunshot wounds and injuries consistent with murder committed with treachery and alevosia. The trial court found the witnesses’ testimony truthful despite minor inconsistencies, attributing these to the witnesses’ initial fear and the delay in reporting the crimes.
Defense and Court’s Rejection of Alibi and Encounter Theory
The appellants claimed the killings arose from an armed encounter with an unidentified group, denying their guilty participation. Testimonies supporting this narrative were found uncredible due to inconsistencies, late reporting, suspicious behavior, and failure to find firearms at the scene. Millora in particular claimed an alibi placing himself in Dagupan City during the killings, but this was contradicted by positive identification by victims’ kin. Tayaba and Mislang also offered alibis, but these were undermined by proximity evidence and suspect testimonies from police officials.
Court’s Findings on Conspiracy and Liability
The trial court initially distinguished roles among the accused, finding Millora principal in one murder and Munoz principal in the others with others as accomplices. The Supreme Court, however, reversed this differentiation, holding that the accused acted in conspiracy. The existence of a predetermined plan to punish the Bulataos, coordinated and executed in concert with weapons ready at all times, sufficed to label all eleven participants as co-principals. The principle that in conspiracy the act of one is the act of all was applied, making each accused equally liable for all three murders.
Nature of the Crime and Applicable Penalty Under the 1987 Constitution
Each killing was murder qualified by alevosia (treachery), as the victims were defenseless and surprised. Under Article 248 of the Revised Penal Code, the penalty for murder ranged from reclusion temporal to death. However, Article III, Section 19(1) of the 1987 Constitution abolished the imposition of death penalty with the proviso that Congress may reinstate it for heinous crimes. Death penalty already imposed is reduced to reclusion perpetua. The Court discussed previous rulings interpreting this provision, particularly whether the penalty for murder should be considered to have three gradations after abolishing the death penalty.
Reconsideration of Penalty Structure Post-Abolition of Death Penalty
The Court reversed prior rulings (People v. Gavarra, Masangkay, Atencio, Intino) that had created three periods within the reduced penalty scale. It held that the abolition of the death penalty does not alter other periods. The constitutional provision forbids imposing death but does not explicitly change the minimum and medium periods of the penalty. The medium period remains reclusion perpetua, while the minimum and maximum periods prescribed by the Revised Penal Code remain intact, except death is replaced by reclusion perpetua.
Legislative Intent and Constitutional Interpretation on Death Penalty
The Court analyzed the records of the Constitutional Commission deliberations, notably statements by Fr. Bernas and other commissioners, confirming the intention to abolish the death penalty as a form of capital punishment. The provision aimed to remove death penalty from statutes but allowed Congress the discretion to restore it for heinous crimes. Until Congress legislates reinstatement, death penalty remains abolished. The Court rejected interpretations that the provision merely suspended the imposition of death penalty without abolishing it, emphasizing the primacy of legislative intent and constitutional spirit over lite
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Case Syllabus (G.R. No. 123294)
Factual Background and Incident Overview
- The case involves the murder of three individuals: Mauro Bulatao, his son Aquilino Bulatao (16 years old), and Alejandro Bulatao, which occurred on June 30, 1972, at Balite Sur, San Carlos City, Pangasinan.
- Eleven men, primarily bodyguards of the town mayor, armed and acting as a private militia, went out in a jeep to find alleged cattle rustlers following a complaint by one of them.
- They proceeded to the Bulatao household, forcibly took the victims, and executed them without trial or mercy, manifesting extreme brutality.
- Mauro Bulatao was shot to death at arm's length by Marvin Millora, observed by his children.
- Aquilino Bulatao was viciously kicked in the head by Feliciano Munoz and later shot to death.
- Alejandro Bulatao was forced along with his wife, and then shot dead by Munoz in cold blood as his son Pedro narrowly escaped being killed.
- The killings were carried out in the presence of terrified family members and exhibited no regard for due process or defense by the victims.
Proceedings and Trial Testimonies
- Four of the accused—Feliciano Munoz, Marvin Millora, Tomas Tayaba, and Jose Mislang—were tried and convicted; Munoz did not appeal, while the others challenged their convictions.
- Testimony from family witnesses (Melecia Bulatao, Jose Bulatao, Juana Bulatao, and Pedro Bulatao) was consistent and detailed, describing the brutal acts and identifying the accused as participants or principals in the murders.
- Medical examiners corroborated the testimony, detailing severe gunshot wounds and physical trauma confirming the acts of execution-style killing and mauling.
- The witnesses delayed reporting due to fear of retaliation by the accused’s group, a factor accepted by the trial court to explain the late denunciations.
- The defense presented contradictory alibi and self-defense claims, alleging a gunfight between unknown armed groups; these claims were rejected due to inconsistency, lack of corroboration, and conflicting physical evidence.
- Positive identification of Millora as the shooter was affirmed by victims' children against his alibi of being elsewhere.
- The court expressed suspicion that certain police officers who testified might have been complicit in the murders as unidentified participants.
Legal Issues and Court’s Findings
- The main legal issue was the guilt of the accused and the appropriate degree of their participation and corresponding penalties.
- The trial court initially differentiated between principals and accomplices, but the Supreme Court found that all eleven men acted in conspiracy with prior agreement to locate and punish the Bulataos.
- The doctrine of conspiracy was applied: each member is liable as co-principal regardless of who fired the shots.
- The murders were qualified by “alevosia” (treachery) because the victims were helpless and defenseless, enhancing the severity of the crime.
- The Constitution’s prohibition on the death penalty was addressed, revisiting the penal scheme for murder under the Revised Penal Code and subsequent constitutional amendments affecting the imposition of penalties.
Penal Code and Constitutional Interpretation on Penalty for Murder
- Article 248 of the Revised Penal Code prescribes penalties for murder ranging from reclusion temporal to death.
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