Title
People vs. Ribadajo
Case
G.R. No. L-40294
Decision Date
Jul 11, 1986
The Supreme Court of the Philippines reduces death sentences to reclusion perpetua for inmates due to insufficient votes, emphasizing the need to evaluate the voluntariness of confessions and aggravating circumstances in sentencing.
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Case Digest (G.R. No. L-40294)

Facts:

  • Case: G.R. No. L-40294, decided on July 11, 1986.
  • Parties: People of the Philippines (plaintiff-appellee) vs. Tobias Ribadajo, Romeo Corpuz, Federico Basas, Rosendo Anor, and Rodolfo Torres (defendants-appellants).
  • Origin: Circuit Criminal Court of Pasig, Rizal; charged with murder in Criminal Case No. CCC-VII-1329-Rizal.
  • Incident Date: November 18, 1971, at approximately 7:55 PM, in New Bilibid Prison, Muntinlupa, Rizal.
  • Defendants: Inmates who planned an attack on a rival group, Brigade 3-A, due to prior humiliation.
  • Method: Used a false key to ambush victim Bernardo Cutamora while he collected food rations.
  • Outcome: Cutamora suffered multiple stab wounds and died, as confirmed by a necropsy report.
  • Confessions: Defendants confessed during a prison investigation; an Information for Murder was filed on April 24, 1973.
  • Arraignment: On July 5, 1973, Ribadajo, Corpuz, and Torres initially pleaded guilty but later retracted, claiming duress.
  • Trial Court Decision: Found all defendants guilty of murder, imposing the death penalty and financial indemnities to the victim's heirs.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the trial court's decision.
  • No reversible error was found in admitting the extrajudicial confessions, recognizing the presence of aggravating circumstances, or imposing the death penalty.
  • Due to insufficient votes, the penalty w...(Unlock)

Ratio:

  • The Supreme Court upheld the admission of extrajudicial confessions, emphasizing the presumption of voluntariness unless evidence of coercion is presented.
  • The confessions included specific details only the accused could know, undermining claims of duress.
  • Treachery was established as the attack was sudden, leaving the victim no chance to defend himself.
  • Ev...continue reading

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