Case Digest (G.R. No. L-19067-68)
Facts:
People of the Philippines v. Edilberto de los Santos, et al., G.R. Nos. L-19067-68, July 30, 1965, Supreme Court En Banc, Reyes, J., writing for the Court.The prosecution (the People of the Philippines) charged numerous inmates of the New Bilibid Prisons in Muntinglupa, Rizal, by two indictments (Criminal Cases Nos. 7703–7704 in the Court of First Instance of Rizal, Pasig). On agreement of the parties the two cases were jointly tried. Of the original forty-five and forty-six accused in the two indictments, some charges were dismissed, some defendants acquitted, and fourteen inmates were convicted and sentenced to death by the trial court: Antonio Marcos, Francisco Flores, Felix Jason, Edilberto de los Santos, Benjamin Armobit, Alejandro Macaso, Carlos Rebano, Jose Garchitorena, Cipriano Castro, Jose Cruz, Jr., Marcial Ama, Alfredo Peralta, Conrado Belen, and Benigno Casulla.
The trial judge conducted an ocular inspection and described squalid, overcrowded conditions in New Bilibid: officially 8,304 prisoners crammed into buildings designed for about 5,000; cells holding many times their capacity; prisoners sleeping on floors and in drainage/toilet areas; meager food allowances; and ineffective, outnumbered guards. The judge narrated the evolution of inmate gangs (notably the Sigue-Sigue and Oxo groups), inter‑gang rivalry, and escalating violence culminating in two mass attacks. Meetings of the Sigue-Sigue on 17 January and on the night of 15 February 1958 were shown to have planned violence; the appointed assault occurred on 16 February 1958 and continued on 17 February 1958.
During the riots Sigue-Sigue members forced open cell doors, released prisoners and brutally clubbed, stabbed, burned and in one instance beheaded several inmates. Nine persons were killed in the two-day span; autopsy reports detailed severe lacerations, skull fractures, puncture wounds, burning and inhuman mutilations. The prosecution introduced testimony of prisoner-witnesses (Leon Catbagan, Jovertino Carces, Marcelino Quirabo, Sotero Bautista, Isidoro Lizardo) and a keeper-in-charge (Francisco Roxas). The defense produced recantation evidence (notably Catbagan later recanted), and many defendants claimed alibi.
The trial court convicted the fourteen named defendants of murder and imposed the death penalty. On review by the Supreme Court (review of the d...(Pro-only)
Issues:
- Did the evidence, including the testimony of prisoner-witnesses and attendant circumstances, prove the fourteen accused guilty beyond reasonable doubt of murder?
- If guilty, was the death penalty properly imposed on the convicted appellants given the circumst...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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