G.R. No. 55285 , June 28, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SIXTO BAYOCOT y SAGUING, defendant-appellant.

FACTS

On June 25, 1979, Gracia Cabrera Dumont, a 56-year-old woman, was returning home via sled after attending court hearings concerning cases she filed against the father of the accused, Sixto Bayocot. While on her property, she encountered Bayocot, who was wearing a raincoat with a hood. When Dumont questioned his presence, her companion, Ananias Aro, recognized Bayocot and noticed a bolo concealed in the sleeve of his raincoat. Aro shouted a warning. As Dumont stepped down from the sled, Bayocot suddenly stabbed her in the back. He then pulled her around and delivered a second fatal stab to her chest. Bayocot later surrendered to the police, admitting the killing and surrendering the bolo.
The defense presented a different narrative. Bayocot claimed he was on the land searching for a lost carabao. He alleged that Dumont scolded him and acted as if she were drawing a weapon from her bag, prompting him to stab her in what he claimed was self-defense. He denied any grudge stemming from the lawsuits, asserting he acted solely because he feared being shot.

ISSUE

The primary issue is whether the killing of Gracia Dumont constitutes murder qualified by treachery, and whether the aggravating circumstance of disregard of age and sex is present.

RULING

The Supreme Court affirmed the conviction for murder but modified the penalty and damages. The Court upheld the trial court’s finding of treachery (alevosia). The attack was sudden and deliberate. Bayocot had concealed his bolo, and the victim, an unarmed elderly woman, was completely helpless and unable to mount any defense against the unexpected assault. This manner of execution, which deliberately ensured the victim’s inability to retaliate, qualifies the homicide as murder.
However, the Court disagreed with the trial court’s finding of the aggravating circumstance of disregard of age and sex. For this circumstance to apply, it must be proven that the offender deliberately intended to offend or insult the victim’s age or sex. The evidence did not establish such specific intent; the attack, while heinous, was primarily motivated by the existing animosity from the court cases. The Court recognized the mitigating circumstance of voluntary surrender, which was not offset by any aggravating circumstance.
Consequently, with murder qualified by treachery and the mitigating circumstance of voluntary surrender, the prescribed penalty was reduced. Applying the Indeterminate Sentence Law, the Court imposed an indeterminate penalty of 17 years and 4 months to 20 years. The Court also increased the civil indemnity to the heirs of the victim from P15,000 to P30,000.