G.R. No. L-46397 - People vs. Dela Cruz

The case involves the People of the Philippines as Plaintiff-Appellee and five accused-appellants – Antonio dela Cruz, Hernando Deo, Reynaldo Arnaldo, Virgilio Baluyot, and Edgardo Marino – who were charged with murder.
The incident occurred on March 8, 1976, at the New Bilibid Prison in Muntinlupa, Metro Manila, while the accused were already serving sentences for previous offenses.

The accused were charged with conspiring, confederating, and using deadly weapons to commit murder against one Mabini Garachico.
The killing was committed under circumstances involving treachery and evident premeditation.
The facts as presented by the prosecution include extra-judicial confessions of the accused, admissions of involvement in the stabbing, and a corroborative necropsy and death certificate of the victim.
The case narrative indicates that while confined at Brigade I-D, the accused managed to escape or be released momentarily, during which they planned and executed the murder.
The prosecution supported its case with a series of exhibits (labeled Exhibits A, B, C, D, etc.) which contained:

Portions of extra-judicial confessions where each accused admitted to aspects of the crime.
Evidence of the improvised weapons used in the commission of the murder.
A sketch matching the weapon to the physical evidence.
Testimony regarding the timing and details of the stabbing, notably around 5:45 P.M. on the day of the offense.

Upon arraignment, in accordance with Section 1, Rule 116 (with reference to Rule 118) of the New Rules, the accused entered pleas of guilty after being fully apprised of their constitutional rights.
Despite the plea of guilty, the mandatory presentation of evidence (as established in Ricalde vs. Villaluz and the case of Epifanio Flores) compelled the prosecution to demonstrate the circumstances of the crime.
The trial court, after hearing the evidence and the admissions of the accused, found them guilty of murder.
The trial court imposed the penalty of death on the accused (except for nuances regarding Edgardo Marino) along with ancillary penalties:

Payment of indemnity (P12,000.00) to the heirs of the victim, jointly and severally.
Payment of P5,000.00 as moral damages and another P5,000.00 as exemplary damages.
Payment of the costs of the proceedings.

The appellants, all of whom had been represented by counsel de oficio, did not raise any substantive legal errors regarding the trial proceedings or the evidence presented.
Instead, counsel de oficio recounted efforts to interview the accused in their prison cells and expressed a lamentable inability to devise a defensible legal strategy.
The brief submitted by counsel de oficio did not challenge the findings of the trial court but instead highlighted:

An acknowledgment that the facts were true.
An inability to argue against due process given that no such violation was evident.
A request for mercy in view of the harsh conditions prevailing in the national penitentiary, which had contributed to the unfortunate sequence of events.

Whether the evidence presented, including extra-judicial confessions and corroborative exhibits, was sufficient to convict the accused of murder beyond reasonable doubt.
Whether the mandatory presentation of evidence was complied with in light of the guilty pleas entered by the accused.

Whether the imposition of the penalty of death on the accused was justified given the surrounding circumstances.
Whether the subhuman and deplorable conditions in the New Bilibid Prison, which the accused cited as contributing to the crime, warranted a mitigating adjustment of the penalty.

Whether the accused’s constitutional rights were fully observed during the arraignment and the subsequent trial, particularly in relation to their understanding of the consequences of pleading guilty.

Whether the conditions in the national penitentiary could be considered as a contributing factor to the commission of crimes by manner of social circumstance or systemic failure, thereby influencing the severity of the imposed sentence.