Case Digest (G.R. No. L-18188)
Facts:
People of the Philippines v. Rafael Lacson, et al., G.R. No. L-18188, February 23, 1961, the Supreme Court En Banc, Per Curiam.The accused-appellants were former Governor Rafael Lacson of Negros Occidental and a group of mayors, chiefs of police, special police (SP) supervisors and guards charged with the murder of Moises Padilla during the period November 11–17, 1951, in and around Magallon, La Castellana, Isabela, Valladolid and Bacolod City. The Information alleged murder with aggravating circumstances (treachery, unnecessary cruelty, night-time/despoblado, use of motor vehicles). At arraignment the accused pleaded not guilty.
At trial the prosecution developed a narrative that Padilla, a Nacionalista candidate for mayor of Magallon, had defied Lacson’s (a Liberal) demand that he withdraw his candidacy; thereafter Lacson allegedly publicly threatened Padilla and ordered his arrest and manhandling. Evidence showed armed SPs under the governor’s control converging on Padilla’s movements, his arrest at Dr. Hermano’s house in Isabela in the early hours of November 15, his repeated maltreatment while in custody in Isabela, Magallon and La Castellana, and his disappearance and later return to Magallon as a corpse bearing multiple gunshot wounds and abrasions. Medical evidence established multiple perforating gunshot wounds, many fired at close range into Padilla’s back. Several prosecution witnesses identified particular SP leaders and policemen as participants in the arrest, torture and final removal of Padilla.
After a trial exceeding two years, the trial court convicted 22 of 27 defendants and sentenced them to death; five were acquitted. Under Section 9, Rule 118 (automatic review) the death sentences were automatically elevated to the...(Pro-only)
Issues:
- Did the trial court commit reversible procedural errors or exhibit bias that vitiated the convictions?
- Did the prosecution prove beyond reasonable doubt that Rafael Lacson is criminally liable as principal by induction for the torture and murder of Moises Padilla?
- Did the prosecution prove beyond reasonable doubt that Manuel Ramos, Joaquin Tolentino, Ernesto Camalon, Norberto Jabonete, Felix Alipalo, Ceferino Laos, and Vicente Hijar were guilty as co-principals/conspirators in Padilla’s murder?
- Were Jose Valencia, Ignacio Altea, Anatalio Vasquez, Jesus Agreda, and Rafael Morada properly convicted as accomplices?
- Should Claudio Montilla, Jose Gayona, Jr., Mariano Pahilanga, Raymundo Adle, Juanito Fernando, Juanito Labaosas, Felix Camarines, Florentino Salgo, and Joaquin ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)