G.R. No. L-38674 - People vs. Regular

The case involved an incident at the New Bilibid Prison on or about November 16, 1970, where members of rival prison gangs clashed.
Accused Alfredo Regular and Arturo de Lara, along with other inmates such as Clemente Valeriano (who later fled), were charged for their participation in a stabbing attack that resulted in the death of prisoner Felipe Ladoy and serious injuries to prisoner Emilio Esparza.
The underlying conflict stemmed from longstanding gang rivalries, with prior incidents (including dart throwing) having set the stage for retaliatory violence.

According to the information, on the specified date the accused, acting together with treachery and evident premeditation, attacked the victims using improvised bladed weapons.
Ladoy sustained multiple stab wounds causing massive blood loss and death, while Esparza was wounded but survived due to his timely defense.
The arraignment of Alfredo Regular and Arturo de Lara occurred on August 7, 1972, during which, with the assistance of counsel de oficio, they pleaded guilty after being informed of the charges.
During arraignment, the judge’s inquiries regarding the understanding of their plea and the inevitable imposition of the death penalty did not include a full explanation of legal terms such as “treachery,” “evident premeditation,” and “recidivism.”

Witnesses testified that on the day of the incident, victims Felipe Ladoy and Emilio Esparza were gathering camote tops near Building 4 when the assailants (including Regular, de Lara, and others) suddenly carried out the attack.
Physical evidence included details of the fatal stab wounds on Ladoy (as confirmed by autopsy) and the multiple lacerations on Esparza noted by the attending physician.
Testimonies described how the suspects exited their dormitory by sawing through iron grills to carry out the attack.
Several prosecution witnesses, including fellow inmates, were called to corroborate the sequence of events and the involvement of the gang members.

Testimonies from de Lara revealed that he was only invited by his gangmates to join the attack and was not part of the prior planning. His statements suggested he acted under peer pressure with little time to deliberate.
Alfredo Regular, on the other hand, claimed non-participation; he testified that he remained inside his brigade throughout the incident and denounced the allegation as stemming from a personal grudge due to a relationship dispute.
Regular also alleged that his confession was coerced during an investigation in conditions that could have affected his free will.

Initially, due to the spontaneous and voluntary confessions (albeit ambiguously rendered), the trial court found both Regular and de Lara guilty of murder (with death penalty imposed for killing Ladoy) and frustrated murder (with a lesser penalty for wounding Esparza).
The court noted the aggravating circumstances of treachery, evident premeditation, and recidivism and explained that these factors necessitated harsh penalties.
Despite the plea of guilty, the trial judge’s failure to fully explain the legal consequences led to ambiguities in the admissions of guilt.

After the plea, further hearings were conducted where the prosecution presented additional evidence including extrajudicial confessions and witness testimonies.
The evidence was later scrutinized for whether it truly established the presence of aggravating circumstances such as treachery and evident premeditation beyond reasonable doubt.
The conflicting nature of the confessions – with de Lara providing mitigating explanatory statements and Regular repudiating parts of his confession on open court – played a role in the appellate review.

Whether the accused’s plea was properly and fully informed given that the court failed to clarify the meaning and consequences (especially concerning aggravating circumstances) of pleading guilty.
The extent to which the absence of a clear explanation on terms like “treachery” and “evident premeditation” affected the voluntariness and clarity of the confession.

Whether the prosecution established beyond reasonable doubt that the crimes were committed with treachery and evident premeditation.
The sufficiency of evidence supporting the imputation of aggravating circumstances such as recidivism.

Whether the selective acceptance of parts of the extrajudicial confessions was proper, especially when some portions mitigated the accused’s criminality.
How the conflicting statements between the open court testimony and prior confessions affected the credibility of the evidence.

Whether the actions of the accused should be characterized as murder and frustrated murder or downgraded to homicide and frustrated homicide due to the absence of foregone aggravating circumstances.
Determining the proper degrees of criminal liability and the corresponding penalties given the evidence on planning and execution.

Whether the involvement of other gang members, who planned the attack, could justifiably be extended as conspiracy against both Regular and de Lara.
If de Lara’s mere presence and eventual participation constituted criminal conspiracy or if his participation was coerced and substantially less deliberate.