Case Summary (G.R. No. 234812)
Charges and Initial Proceedings
Bonifacio and Sergio Patotoy were charged with murder, alleged to have occurred during a confrontation following a fistfight at the wedding. The information stated that both accused "confederated together" and acted with intent to kill, taking advantage of "superiority of strength" to stab Verano multiple times, resulting in his instantaneous death.
Prosecution's Evidence
The prosecution's case was built on testimonies from witnesses present at the scene. Evidence indicated that Manuel Verano danced with Sergio Patotoy's wife, which led to a fistfight between him and Sergio. After the confrontation, Bonifacio was informed by an acquaintance of the incident and subsequently encouraged by his father to confront and kill Verano. Witnesses described that Bonifacio retrieved a knife and attacked Verano, which was corroborated by medical findings indicating fatal stab wounds.
Defense and Testimony
In his defense, Bonifacio admitted to killing Verano but denied his father's participation, claiming he acted out of confusion during a confrontation. He stated that upon arriving at Verano’s house, he heard the victim threatening to kill someone, which he interpreted as an imminent danger. However, the prosecution showed that Bonifacio's version lacked credibility and did not support his claim of self-defense.
Trial Court Decision
On May 15, 1991, the Regional Trial Court convicted Bonifacio Patotoy of murder, imposing the penalty of Reclusion Perpetua, while ordered him to indemnify the victim's heirs with P50,000. The court did not find merit in Bonifacio’s claim of self-defense, ruling that he did not demonstrate sufficient justification, such as unlawful aggression from Verano. The court noted that the mitigating circumstance of voluntary surrender was outweighed by treachery, as Bonifacio and his father attacked the victim without warning after a prior confrontation.
Appeals and Legal Principles
Bonifacio appealed the conviction, arguing self-defense and challenging the presence of aggravating circumstances, namely treachery, evident premeditation, and superior strength. However, the appellate court upheld the trial court's findings, confirming that the evidence did not establish unlawful aggression and that the circumstances of the attack suggested premeditation rather than self-defense.
Ruling on Self-Defense and Aggravating Circumstances
The court clarified that self-defense must be proven unequivocally by the accused when claiming it as a justification for a fatal act. The required
...continue readingCase Syllabus (G.R. No. 234812)
Case Background
- The case involves Bonifacio Patotoy, who appeals a conviction for murder regarding the fatal stabbing of Manuel Verano.
- The Regional Trial Court of Masbate, Branch 44, found him guilty in Criminal Case No. 6015.
- The information alleges that, on February 7, 1990, both accused, confederating together, attacked and stabbed Manuel Verano, resulting in his instantaneous death.
Incident Description
- The incident occurred during a wedding celebration in Barangay Sawang, Uson, Masbate.
- During the festivities, a confrontation arose when Manuel Verano danced with Sergio Patotoy's wife, irking Sergio.
- A physical altercation ensued between Sergio and Manuel, prompting a fistfight that was eventually broken up by bystanders.
Sequence of Events Leading to the Stabbing
- Following the fistfight, Sergio returned home to retrieve a bolo (a type of knife).
- Bonifacio, informed by a friend about the fight, went to the plaza to inquire about the incident and was encouraged by his father to confront Manuel.
- Armed with a knife, Bonifacio ran towards Manuel's house, where he confronted the victim and fatally stabbed him.
Details of the Assault
- Bonifacio approached Manuel, questioning him about the previous encounter with his father before attacking with a knife.
- Witnesses described the stabbing, where Manuel staggered and fell after bei