Case Summary (G.R. No. L-29889)
Initial Incident and Arrest
On the evening of January 2, 2005, Felix Sabasan y Magango was fatally attacked and stabbed multiple times outside his home. Following the attack, Yulo and Bueno were identified as the culprits and were arrested early in the morning of January 3, 2005, in possession of a blood-stained ice pick.
Charges Filed
An Information for murder was filed against Yulo and Bueno on January 6, 2005, alleging that they conspired with an unidentified accomplice to kill Felix with intent and treachery. Upon arraignment, both defendants pleaded not guilty.
Evidence Presented
During the trial, the prosecution presented four witnesses: Lucena Abayon, Nehemias Sabasan, Cristy Cardinal, and Police Chief Inspector Jose Arnel Marquez. Witness Abayon testified that she saw Yulo and Bueno chase and subsequently stab Felix. Nehemias, Felix's father, corroborated this by stating Felix identified his attackers before dying from his wounds. Cardinal testified that Yulo confessed to her about the stabbing, while PCI Marquez confirmed the fatal nature of Felix's injuries.
Defense and Testimonies
In their defense, Yulo and Bueno maintained that they were at their employer's house during the stabbing and were arrested without proper cause. They claimed credible inconsistencies regarding the testimonies of the prosecution witnesses, particularly Abayon's actions following the incident. Bueno further stated that he was surprised by his implication in the crime as he had no prior conflict with Felix.
RTC Decision
On November 14, 2016, the Regional Trial Court (RTC) convicted Yulo and Bueno of murder, emphasizing the credibility of eyewitness testimonies and Felix's dying declaration. The RTC sentenced both to reclusion perpetua and ordered them to indemnify Felix’s heirs.
Appeal to the CA
After the RTC ruling, Yulo and Bueno appealed the decision to the Court of Appeals (CA), which affirmed the RTC ruling on March 4, 2019, citing sufficient evidence of guilt, including the dying declaration and Yulo's admission to Cardinal. The CA, however, modified the damage awards to Felix's heirs, increasing the amounts.
Grounds for Reversal
In their appeal to the Supreme Court, Yulo and Bueno contended that there were reversible errors in the previous decisions, challenging the weight of evidence and the findings of treachery and abuse of superior strength.
Supreme Court Ruling
The Supreme Court upheld the lower courts' convictions. It outlined the essential elements of murder as defined in Article 248 of the Revised Penal Code and concluded that all elements were met with the evidence presented. Specifically, the Court recognized the positive identification of the accused-appellants and the conspiracy between them as the assailants.
Findings on Treachery and Abuse of Superior Strength
While the RTC and CA found treachery present in the killing, the Supreme Court disagreed, asserting that there was a chase prior to the attack and Felix had a chance to escape
...continue readingCase Syllabus (G.R. No. L-29889)
Case Overview
- The case revolves around the appeal of Mark Anthony Yulo y Gallo and Mark Ryan Bueno y Corona against their conviction for murder.
- The appeal was filed under Rule 124 of the Revised Rules of Criminal Procedure, seeking to reverse the decision of the Court of Appeals (CA) dated March 4, 2019.
- The CA had affirmed the Regional Trial Court (RTC) decision that found the accused guilty beyond reasonable doubt of murder as defined by Article 248 of the Revised Penal Code (RPC).
Factual Background
- On the evening of January 2, 2005, Felix Sabasan y Magango was stabbed multiple times outside his residence in Sitio Culasisi, Brgy. San Luis, Antipolo City.
- Yulo and Bueno were identified as the perpetrators and arrested shortly after the incident, with a blood-stained ice pick found in Yulo's possession.
- An Information for murder was filed against them on January 6, 2005, detailing their intent to kill Felix with the use of a bladed weapon.
Arraignment and Trial
- Both accused pleaded "not guilty" during their arraignment.
- The trial commenced after pre-trial stipulations on jurisdiction and identities were established.
- The prosecution presented four key witnesses: Lucena Abayon, Nehemias Sabasan, Cristy Cardinal, and Police Chief Inspector Jose Arnel Marquez.
Prosecution's Evidence
- Lucena Abayon witnessed the attack and identified Yulo and Bueno, stating they chased Felix and that Yulo stabbed him.
- Nehemias Sabasan, Felix's father, testified that Felix identified Yulo and Bueno as his attackers before succumbing to his injuries.
- Cristy Cardinal testified that Yulo confessed to her about stabbing Felix.
- PCI Marquez provid