Case Digest (G.R. No. L-32205)
Facts:
The People of the Philippines v. (thirty-seven accused), G.R. No. L-32205, August 31, 1979, Supreme Court En Banc, Aquino, J., writing for the Court. This case arose from a mass assault and killings that occurred on June 27, 1965 at the jailhouse (bartolina) of the Davao Penal Colony in Panabo, Davao del Norte. The bartolina was a two‑story building with a large overcrowded cell (about 80 sq. meters) on one side and three small “close‑confined” cells on the opposite side; about 70–75 prisoners were in the large cell and 17 prisoners were in the small cells. Two prison gangs — the Visayan Oxo gang and the Luzon Sigue‑Sigue gang — divided the inmates.On the morning in question a prisoner‑trustee, Numeriano Reynon, was on guard duty. Using a ruse (a pillow pawn transaction), a close‑confined prisoner, Leocadio Gavilaguin, and his companions assaulted Reynon, obtained the keys, and sixteen prisoners from the close‑confined cells (led by Emerito Abella, Agustin Villaflor and Gavilaguin) entered the big cell armed with improvised weapons. They were joined by a number of inmates from the big cell; the attackers surprised the unarmed victims, locked/obstructed the door, and for about an hour stabbed and beat many inmates. Fourteen prisoners were killed and several others grievously injured; ten victims were pronounced dead on arrival and four more died in hospital. The assault was stopped only when the prisoners were assured they would not be maltreated and surrendered; weapons and keys were returned to prison officials.
Investigations followed: sworn statements of inmates were taken in July 1965; a complaint was filed on September 24, 1965 in the municipal court of Panabo; an information was filed in the Court of First Instance of Davao (Criminal Case No. 9405) on October 22, 1965. At arraignment, nineteen accused pleaded guilty and ratified extrajudicial confessions sworn before the municipal judge; the trial court in a partial decision (March 5, 1966) convicted these nineteen of the complex crime of multiple murder and multiple frustrated murder (with aggravating circumstances) and sentenced eighteen to death and one to reclusion perpetua. The remaining eighteen were tried; after trial the lower court (decision of September 14, 1969) convicted twelve of those eighteen and sentenced them to death, acquitted six. In sum, thirty of the thirty‑seven accused were sentenced to death; some sentenced accused subsequently died in custody or escaped. The death sentences were before the Supreme Court on automatic review "as law and justice shall dictate."
At the Supreme Court, the issues included the validity of pleas and confessions (many were extrajudicial and took place before the 1973 Constitution), sufficiency of evidence for those who pleaded not guilty, propriety of treating the killings as a single complex crime (multiple murder) under Article 48 of the Revised Penal Code,...(Subscriber-Only)
Issues:
- Were the extrajudicial confessions and the guilty pleas of those who pleaded guilty valid and properly accepted by the trial court?
- Was the evidence sufficient to convict the nine accused who pleaded not guilty beyond reasonable doubt?
- Did the facts support conviction for a complex crime of multiple murder/multiple frustrated murder (one complex offense under Article 48) rather than separate counts for each killing, and were aggravating circumstances present to justify the imposed penalties?
- Was the death pe...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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