Title
People vs. Gonzales
Case
G.R. No. L-34674
Decision Date
Aug 6, 1979
Prisoner Gonzales pleaded guilty to murdering fellow inmate Malines; court upheld death penalty, affirming treachery and premeditation despite lack of eyewitnesses.

Case Digest (G.R. No. 201151)
Expanded Legal Reasoning Model

Facts:

  • Procedural History and Plea Entry
    • Pablo Gonzales was charged with Murder in Criminal Case No. CCC-VII-883-Rizal, with the information alleging that on April 9, 1971, at the New Bilibid Prison in Muntinglupa, Rizal, he, while confined, attacked Moises Malines using an improvised bladed weapon.
    • Initially, Gonzales pleaded not guilty; however, during trial the day after the scheduled trial, he expressed his wish to withdraw his plea of not guilty and substitute it with a plea of guilty.
    • The court re-arraigned him in accordance with Section 1, Rule 116 of the New Rules of Court, and upon being questioned about his understanding of the consequences—including the imposition of the death penalty—Gonzales confirmed his voluntary plea of guilty.
  • Presentation of Evidence and Witness Testimonies
    • Testimony of Cecilio de Leon:
      • Stated that around 3:00 PM on the day of the incident, he observed three prisoners loitering outside the neuropsycho ward and saw the accused among them.
      • Witnessed the group entering the ward with improvised bladed (cutting) weapons and noted the ensuing commotion, correlating the entry with the attack on Moises Malines.
    • Testimony of Brigildo Amon:
      • Confirmed that he was stationed near the door of the ward and saw the accused and his companions loitering and then enter the ward brandishing their weapons.
      • Noted the presence of Moises Malines found lying at a passage (“tarima”) after the assailants left.
    • Medical Evidence by Dr. Ernesto Brion:
      • As the NBI Assistant Director for Medicine, he testified based on the necropsy report, which recorded that Moises Malines sustained 22 stab wounds, two of which were fatal.
    • Additional Evidence by Jesus Tumagan:
      • Identified the weapon used in the stabbing and presented the extra-judicial confession of the accused.
      • The confession indicated that Gonzales and his companions committed the murder in retaliation for the killing of a fellow prison gang member the previous day.
  • Court Proceedings on Evidence and Objections
    • Counsel de oficio for the accused objected to the admission of the extra-judicial confession on the ground that it was taken contrary to the accused’s will.
    • Although reserving the right to file a motion to dismiss or present additional evidence, counsel ultimately did not file such a motion nor present further testimony or evidence.
    • The court, while accepting the plea of guilty, also directed the presentation of factual evidence to comply with the doctrine established in People versus Epifanio Flores.
  • Judgment and Sentencing
    • On September 9, 1971, the trial court rendered judgment finding Gonzales guilty of Murder, sentencing him to the penalty of death.
    • The judgment also included orders to indemnify the heirs of the victim, Moises Malines, with P12,000.00, in addition to the payment of moral damages, exemplary damages, and court costs.
    • A subsequent appeal was made alleging that the acceptance of the plea of guilty was precipitate; however, the appellate court ultimately affirmed the trial court’s decision, finding that proper judicial safeguards were in place.

Issues:

  • Validity and Timing of the Plea of Guilty
    • Whether the accused’s substituted plea of guilty was entered voluntarily and with full knowledge of its consequences, especially the possibility of a death sentence.
    • Whether the court adequately ensured that the accused comprehended the nature of the charges and the severe penalty to be imposed before accepting his plea.
  • Sufficiency and Admissibility of the Evidence
    • Whether the circumstantial evidence—including the witness testimonies, necropsy report, and extra-judicial confession—was sufficient to establish the crime beyond reasonable doubt.
    • Whether the absence of an eyewitness directly observing the killing affects the determination of qualifying circumstances like treachery and evident premeditation.
  • Establishment of Qualifying Circumstances
    • Whether the facts and inferences drawn from the sequence of events support the presence of treachery in the manner the accused and his companions executed the attack.
    • Whether evident premeditation was clearly demonstrated, particularly in light of the accused’s own extrajudicial confession to planning the murder in retaliation for a prior incident within their prison gang.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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