G.R. No. L-32571-72 - People vs. Pajarillo

Two separate informations were filed against the accused in the Circuit Criminal Court of Rizal:

Both informations stemmed from a violent melee on December 6, 1969, at the Muntinlupa Penitentiary involving rival prison gangs: the BRM (Bicol Region Masbate) and the “Sigue-Sigue Sputnik.”
The fatal events occurred following a riot, resulting in the stabbing deaths of the victims and injuries to other inmates.

The accused, Juanito Pajarillo and Almario Rodriguez, were first arraigned on September 14, 1970, and initially pleaded not guilty.
On the first day of trial (September 16-17, 1970), acting with the assistance of their de oficio counsel, Atty. Jose Galvan, both accused withdrew their plea of not guilty and voluntarily pleaded guilty.
The trial court informed them that a guilty plea would result in the imposition of the death penalty, as provided by law.
Upon confirmation of their guilty plea—after having the informations read by an interpreter—the court promptly pronounced death sentences in each case, thereby admitting all material allegations contained in the informations.

The accused were imprisoned at New Bilibid Prisons and were members of the BRM gang.
They were alleged to have conspired with other unidentified inmates (“John Does”) to attack rival gang members with treachery, evident premeditation and alleged abuse of superior strength.
In the case of Roque Danao, the accused’s stab wounds caused the victim’s death through multiple injuries.
Similarly, in the case of Reynaldo Guevarra, the attack involved a stabbing assault that resulted in the victim’s death.

Testimonies and postmortem examination by Dr. Ricardo Ibarrola indicated that the cause of death was due to multiple stab wounds.
Prison reports and statements, including that of appellant Pajarillo admitting to stabbing the victim in the abdomen three times, implying a frontal attack.

The occurrence of a melee between rival prison gangs during which two inmates died and several were wounded.
The absence of corroborative evidence for some of the aggravating circumstances alleged (e.g., abuse of superior strength and treachery).

The central issue at trial was whether the trial court properly accepted the plea of guilty and imposed the death penalty without requiring further evidence on the circumstances surrounding the crimes.
Concerns were raised about the possibility of an improvident plea, considering that the accused might not have fully understood the implications and the evidentiary basis of the charges, specifically regarding the alleged aggravating circumstances.

Whether the trial court erred in accepting the voluntary plea of guilty without requiring the adduction of evidence concerning both the guilt and the attendant circumstances of the crime, thereby potentially facilitating an improvident plea.
Whether the presentation (or lack thereof) of evidence sufficient to establish the qualifying and aggravating circumstances—especially treachery, abuse of superior strength, and evident premeditation—was proper and compliant with legal requirements in a capital case.
Whether the imposition of the death penalty, based solely on the plea of guilty and without additional evidence, was constitutionally and legally justified.
The propriety and sufficiency of awarding moral and exemplary damages without the presentation of concrete evidence of pecuniary loss.