G.R. No. L-15633 - People vs. Ala y Duran

The case involves the crime of murder committed within the confines of the New Bilibid Prison, municipality of Muntinlupa, Rizal, Philippines, on or about March 24, 1959.
Defendant Primitivo Ala, along with Nicolas Mojica, was charged with the murder of their co-prisoner, Ruperto Artus y Garcia.
The information stated that the accused, armed with deadly, sharp-pointed instruments, committed the stabbing of Artus with evident premeditation and treachery.

The murder, executed through multiple stab wounds, was described in detail, including the nature, location, and number (thirty-two wounds) of the injuries sustained by the victim.
The killing was positioned as a calculated act of vengeance amid a milieu of prison gang rivalries, notably involving the “OXO Gang” (to which Ala and Mojica belonged) and the “Sigue-Sigue Gang.”
The crime was further aggravated by the fact that Ala was a quasi-recidivist, having previously been convicted and serving a sentence by final judgment at the time of the incident.

Upon arraignment, a significant point in the proceedings was that Primitivo Ala pleaded guilty, while his co-accused, Nicolas Mojica, pleaded not guilty.
The trial process was expedited given the criminal background of Ala and the overwhelming evidence supporting the facts of the case.
The lower court rendered judgment sentencing Ala to the extreme penalty (i.e. the death penalty) and ordered him to indemnify the heirs of the deceased Ruperto Artus a sum of P6,000, in addition to the payment of costs.

A transcript from the lower court proceedings was attached to the record, which detailed the events during arraignment and the plea.
The transcript revealed that counsel for Ala explained the contents of the information to him fully, including the consequences of his plea.
The court, through inquiries and corroboration with the transcript, ascertained that Ala confirmed his understanding by answering affirmatively to questions regarding the nature of the charges, his free volition in pleading guilty, and the consequent legal implications.
Although initially there were concerns raised by counsel de oficio regarding the sufficiency of the evidence and the reliability of hearsay evidence, the transcript provided adequate clarity on the accused’s full awareness.

The murder was executed as an act of revenge following the killing of Gabriel Buclatin, a leader of the “OXO Gang,” by members of the "Sigue-Sigue Gang" inside the prison.
That evening, the retaliatory plan was set in motion by Ala and Mojica, resulting in the stabbing of Ruperto Artus using both a flat-pointed instrument and an improvised ice-pick-like weapon.
The detailed forensic and medical examination report described the exact locations and types of puncture wounds inflicted on the victim, confirming death by shock and passive internal hemorrhage.

Whether defendant Primitivo Ala, by pleading guilty, was adequately informed of the nature of the charges against him and the consequences of his plea.

The central question revolved around the extent of Ala’s knowledge regarding the factual allegations and legal implications of his plea.
Whether the plea was entered voluntarily and intelligently after due explanation by his counsel.

Whether the absence of complete evidence in the case record (initially due to incomplete transcript issues) could undermine the finding that Ala was fully aware of his rights and the gravity of the charge.

The issue of whether the plea of guilty was essentially a calculated survival strategy given Ala’s status as a quasi-recidivist already serving a sentence, thereby invoking a potential bias towards an appeal for leniency.

Whether the sufficiency of the evidence, including the detailed transcript and corroborative evidence from the co-defendant’s conviction, justifies the imposition of the extreme penalty notwithstanding the doubts raised by both parties’ counsel.