GR 79619; (August, 1990) (Digest)
G.R. No. 79619 , August 20, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO BUEZA, defendant-appellant.
FACTS
The accused, Antonio Bueza, was convicted of Murder by the Regional Trial Court of Iriga City for the killing of Juanito Rosela. The prosecution evidence established that on the evening of March 8, 1983, Bueza and his co-accused, Rodolfo Solis, both armed and intoxicated, went to the victim’s house. Solis attempted to drag the victim’s wife, Nilda Rosela, to a dark place. When she resisted, Solis threw stones at the house, awakening Juanito. Juanito armed himself with a bow and arrow, but a struggle ensued. The accused then assaulted, dragged, and struck Juanito with stones. His body was discovered buried three days later, bearing multiple fatal injuries.
The Court of Appeals, upon review, determined the proper penalty to be reclusion perpetua and certified the case to the Supreme Court. The appellant contested his conviction, arguing that the lone eyewitness did not actually see the killing, that her testimony was inconsistent, and that his extrajudicial confession was invalid.
ISSUE
The core issue is whether the guilt of the accused for the crime of Murder was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the factual findings of the trial court and the Court of Appeals, giving credence to the testimony of Nilda Rosela. While she did not witness the final act of burial, she positively identified Bueza and Solis as the assailants who initiated the attack on her and her husband. Her testimony on the material events was consistent and credible. The Court also found the extrajudicial confession, given after being informed of his constitutional rights, to be admissible and corroborative of other evidence.
Crucially, the Court ruled that the killing was attended by treachery (alevosia). The medical findings indicated the victim was first rendered defenseless by wounds to his leg joints before being fatally attacked. This method of attack, deliberately employed to ensure the execution of the crime without risk to the assailants from any defense the victim might make, qualifies as treachery. The aggravating circumstance of nocturnity (nighttime) was correctly held to be absorbed by treachery. With treachery present and no mitigating circumstance, the proper penalty is reclusion perpetua. The civil indemnity was also increased to Thirty Thousand Pesos (P30,000.00).