Case Summary (G.R. No. 39085)
Trial Court Findings
Eyewitnesses, including the brigade chief inmate Villafuerte, testified that Yabut wielded the wooden club (Exhibit C) and attacked Aseo without provocation. Yabut attempted to resist disarming and threatened Villafuerte, then fled and hid in a latrine before being captured by another prison guard inmate. The court rejected Yabut’s claim that Villafuerte delivered the fatal blow.
Medical Evidence
Two physicians—Dr. Santiago Estrada (Bureau of Prisons) and Dr. Pablo Anzures (University of the Philippines Medico-Legal Department)—confirmed that Aseo’s death resulted from skull fracture and ensuing hemorrhages. Their testimony corroborated that the blows were delivered from behind and inflicted with treacherous intent.
Assignments of Error on Appeal
- Misapplication of Article 160, RPC
- Failure to credit and corroborate defense evidence
- Erroneous finding of qualifying circumstance of treachery (alevosia)
- Insufficient proof of murder beyond reasonable doubt
Interpretation of Article 160, RPC
Article 160 mandates that any convict who commits a new felony while serving sentence shall receive the maximum penalty prescribed for the new offense. The Court held that neither the Spanish text nor the original intent of Article 160 limits its application to crimes different in character from the one for which the convict is serving time. Headnotes and captions serve only as catchwords and cannot override clear statutory language.
Treachery and Degree of Homicide
While the evidence plainly established that Yabut acted with intent to kill and inflicted lethal blows, some members of the Court expressed reasonable doubt as
Case Syllabus (G.R. No. 39085)
Case Title
- G.R. No. 39085, 58 Phil. 499 (September 27, 1933)
- Plaintiff-Appellee: The People of the Philippine Islands
- Defendant-Appellant: Antonio Yabut
Facts of the Case
- On or about August 1, 1932, in Manila’s Bilibid Prison, Antonio Yabut, then serving sentence for homicide, assaulted fellow prisoner Sabas Aseo.
- The assault occurred between 7:30 and 8:00 PM inside Brigada 8-A (a prison gang of over 150 inmates) under Chief Squad Leader José Villafuerte and assistant Vicente Santos.
- Other members present included Apolonio Saulo, Isaias Carreon, Melecio Castro, Mateo Bailon, and the Moros Taladie and Hasan.
- Yabut first confronted Carreon, threatening to slap him unless Carreon “collected” a debt owed by another inmate. Carreon then struck Apolonio Saulo, rendering him unconscious.
- As Villafuerte rose to fetch his authorized baton, he saw Yabut strike Sabas Aseo twice from behind with a wooden club (Exhibit C): first to the nape, causing Aseo to bend forward, then a second blow to the head, after which Aseo fell.
- Villafuerte rushed Yabut, who threatened to kill him if he approached. A struggle ensued, Yabut tried to strike Villafuerte; the two grappled until Villafuerte’s baton slipped from his grasp.
- Yabut freed himself, fled to the far end of the barracks, hid in the latrine, and was immediately captured by Prison Sergeant Proceso Carangdang.
- Aseo died approximately twenty-four hours after the assault, his skull fractured.
Medical and Eyewitness Testimony
- Dr. Santiago Estrada (Resident Physician, Bureau of Prisons) and Dr. Pablo Anzures (Medico-Legal Dept., University of th