Case Digest (G.R. No. 132376) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The People of the Philippines vs. Amadeo Peralta, et al. (G.R. No. L-19069, October 29, 1968), six inmates of the New Bilibid Prison at Muntinglupa—Amadeo Peralta, Andres Factora, Leonardo Dosal, Angel Parumog, Gervasio Larita and Florencio Luna—were among twenty-two charged with the February 16, 1958 multiple murders of fellow convicts Jose Carriego, Eugenio Barbosa and Santos Cruz. The victims, all Tagalogs and known “Sigue-Sigue” gang members confined in Building 4, were attacked by OXO gang inmates from brigade 4-A armed with clubs and improvised ice-picks. After preliminary motions, one accused was dismissed for lack of evidence; six more were dropped for failure to establish a prima facie case; one died during trial; eight were acquitted. The Court of First Instance of Rizal found the remaining six guilty of three counts of murder with aggravating circumstances—treachery, abuse of superior strength, commission by a band and quasi-recidivism—and sentenced each to death, Case Digest (G.R. No. 132376) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of Prison Gangs
- Since 1956, New Bilibid Prison inmates formed two rival gangs:
- “Sigue-Sigue” (predominantly Tagalogs) housed in Building 1.
- “OXO” (predominantly Visayans/Mindanaoans) housed partly in Building 4 (brigade 4-A).
- Frequent violent clashes led to segregation of rival members into separate buildings and brigades.
- Events of February 16, 1958
- About 7:00 a.m., inmates assembled for Sunday mass; a fight between two rival members in the plaza was quelled by guards.
- A riot erupted in Building 1; Sigue-Sigue inmates attempted to invade Building 4 but were repelled.
- Shortly thereafter, OXO members in brigade 4-A destroyed their lock, invaded 4-B, and killed Jose Carriego by clubbing and stabbing.
- The same group forced entry into 4-C, broke in with insider help, and killed Eugenio Barbosa and Santos Cruz by blows and stabbings.
- Victims’ Injuries and Causes of Death
- Jose Carriego:
- Lacerated lower lip; contusion on neck; five chest punctures.
- Cause of death: internal hemorrhage from chest wounds.
- Eugenio Barbosa:
- Occipital laceration; two abdominal penetrating wounds; axillary laceration; bruises.
- Cause of death: shock and internal hemorrhage.
- Santos Cruz:
- Head laceration; fractured skull; lip cut; seven chest punctures; hand hematomas.
- Cause of death: fractured skull.
- Prosecution Evidence
- Brigade 4-B witnesses (Pineda, Marayoc, Sauza) saw Factora club Carriego and Peralta, Dosal stab him.
- Brigade 4-C witnesses (Fontillas, Pabarlan, Halili, Espino) identified Factora, Peralta, Dosal, Parumog, Larita, Luna in the killings of Barbosa and Cruz.
- Defendants and Procedural Posture
- Six review defendants: Amadeo Peralta, Andres Factora, Leonardo Dosal, Angel Parumog, Gervasio Larita, Florencio Luna.
- Others were dismissed, acquitted, or died; conviction and death sentences of these six were automatically reviewed by the Supreme Court.
Issues:
- Whether conspiracy existed among the six in planning and executing the three murders.
- Whether Peralta’s and Dosal’s self-defense claims negate their guilt.
- Whether Parumog’s, Larita’s, and Luna’s alibi defenses negate their participation.
- Whether aggravating circumstances (quasi-recidivism, treachery, abuse of superior strength) are present.
- Whether multiple death penalties are proper for each defendant under the Revised Penal Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)