Case Digest (G.R. No. L-44187)
Facts:
The People of the Philippines v. George Daeng and Rolando Castillo, G.R. No. L-44187, November 12, 1981, Supreme Court En Banc, Concepcion Jr., J., writing for the Court. The prosecution (plaintiff-appellee) charged George Daeng and Rolando Castillo (defendants-appellants), together with Conrado Bautista and Gerardo Abuhin, with the murder of inmate Basilio Beltran on December 13, 1970 at the New Bilibid Prison, Muntinlupa; the information was filed June 18, 1971.On June 29, 1971 the trial court sentenced all four to death based on their spontaneous and voluntary confessions. The Supreme Court, upon automatic review in G.R. No. L-34091 (People v. George Daeng, et al., Jan. 30, 1973), set aside the judgment and remanded for a new arraignment because the accused had not been adequately made to understand the nature and consequences of a guilty plea. At arraignment on March 10, 1973 all four pleaded not guilty; before the prosecution rested, Daeng and Castillo withdrew to plead guilty and were sentenced to death on September 1 and 15, 1973 respectively.
Those convictions were again remanded pursuant to the doctrine in People v. Epifanio Flores for mandatory presentation of evidence. At a third arraignment on February 19, 1976 Daeng and Castillo again pleaded guilty; the prosecution then presented witnesses (NBI medico-legal officer, prison guards and an eyewitness) and documentary evidence including their sworn statements and the necropsy report. The trial court found the killing attended by treachery, evident premeditation, obvious ungratefulness and that it was committed while the accused were serving sentence; it again imposed the death penalty and ordered civil indemnities and damages (the court’s original dispositive portion likewise referenced Section 32, Rule 138, and recommended commutation under Article 5, RPC).
The present decision is the Court’s mandatory review of that judgment. The appellants raised six assignments of error challenging (inter alia) the trial court’s failure to follow the prior remand direction, the presence of qualifying and aggravating circumstances (treachery, evident preme...(Pro-only)
Issues:
- Did the trial court err in failing to comply with the Supreme Court’s remand instructions in G.R. No. L-34091 (procedural question)?
- Were the qualifying and aggravating circumstances of treachery, evident premeditation and obvious ungratefulness proven beyond reasonable doubt (substantive)?
- Was the killing committed while the appellants were serving sentence by virtue of a final judgment, thereby invoking Article 100 of the Revised Penal Code (substantive)?
- Was the conviction for murder and imposition of th...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)