Case Digest (G.R. No. L-19069)
Facts:
The People of the Philippines v. Amadeo Peralta, et al., G.R. No. L-19069, October 29, 1968, the Supreme Court En Banc, Per Curiam.The prosecution (plaintiff-appellee) charged twenty-two inmates of the New Bilibid Prison with multiple counts of murder arising from a prison riot on February 16, 1958; among those tried, six — Amadeo Peralta, Andres Factora, Leonardo Dosal, Angel Parumog, Gervasio Larita and Florencio Luna — were convicted by the Court of First Instance of Rizal and sentenced to death with indemnity and costs, and the case was brought to the Supreme Court on automatic review (death-penalty case). Prior to final disposition by the trial court, the provincial fiscal moved to dismiss the charge against one accused for lack of evidence; after the prosecution rested, charges against six other accused were dismissed for failure to make a prima facie case; one accused died during the proceedings; and the trial court acquitted eight additional defendants.
Factual background at trial showed that since 1956 inmates had been organized into two rival gangs, the Tagalog-dominated "Sigue-Sigue" and the Visayan/Mindanao-dominated "OXO." On the morning of February 16, 1958 a disturbance in the prison plaza precipitated a sequence of riots and an organized invasion by inmates of brigade 4-A (an OXO lair) into other brigades of Building No. 4. The attackers, armed with clubs, ice-picks and improvised weapons, singled out and killed three Tagalog inmates — Jose Carriego, Eugenio Barbosa and Santos Cruz — inflicting multiple fatal wounds. Medical testimony described the fatal injuries and causes of death for each victim.
Prosecution eyewitnesses — fellow inmates Romeo Pineda, Juanito Marayoc, Avelino Sauza, Oscar Fontillas, Antonio Pabarlan, Jose Halili, Carlos Espino and others — identified Factora, Peralta, Dosal, Parumog, Larita and Luna among the assailants, and recounted coordinated acts (breaking locks, bolting doors, selectively pulling out Tagalogs, and stabbing/clubbing victims). Defendants offered defenses of self-defense (Peralta, Dosal, Factora) or alibi (Parumog, Larita, Luna). The trial court credited the prosecution witnesses, rejected the exculpatory claims, found that conspiracy and certain aggravating circumstances (treachery as to Carriego; abuse of superior strength as to Barbosa and Cruz; quasi-recidivism) attended the killings, and convicted the six defendants of murder, sentencing them to death and ordering indemnities of P6,000 to heirs of each victim.
On automatic review the Supreme Court examined (i) whether conspiracy attended the murders, (ii) whether evident premeditation ex...(Subscriber-Only)
Issues:
- Did the evidence establish a conspiracy among the accused so as to render each guilty as co-principal of the three murders?
- Was the aggravating circumstance of evident premeditation present?
- May the Court lawfully impose multiple death penalties on each conspirator for the three murders?
- Did the special aggravating circumstance of quasi-recidivism apply so as to require imposing the...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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