G.R. No. L-40294 - People vs. Ribadajo

The case involves the conviction and sentencing of six accused inmates from the New Bilibid Prison, all of whom belonged to the same brigade (3-C) in Muntinlupa, Rizal.
The incident in question occurred on November 18, 1971, during the distribution of food rations to inmates of brigade 3-A.

On November 18, 1971, at approximately 7:55 p.m., inmates from brigade 3-C executed a plan during the rations distribution wherein they used a false key (a tin can) to open the door of their dormitory.
With the door opened, the accused rushed toward the area where inmates of brigade 3-A had gathered for their rations, simultaneously attacking the victim, Bernardo Cutamora, with bladed weapons.
The attack resulted in multiple stab wounds inflicted on various parts of the victim's body, with the subsequent necropsy report (Exhibit ‘A’) confirming that these injuries caused his death.

Prior to the attack, around 1:00 p.m. on the same day, the accused allegedly held a meeting and planned to kill any inmate from brigade 3-A.
Their motive was rooted in longstanding animosity; they claimed they were avenging previous mockery and humiliation by inmates of brigade 3-A, who had once thrown human waste at them and ridiculed their abilities.

An investigation by the New Bilibid Prisons’ Investigation Section on November 20, 1971, led to the collection of statements from the accused, all of whom admitted to participating in the slaying of Bernardo Cutamora.
The initial Information for Murder was filed on April 24, 1973, before the then Circuit Criminal Court of Pasig, Rizal.
During arraignment on July 5, 1973, accused Tobias Ribadajo, Romeo Corpuz, Loreto Rivera (who later died), and Rodolfo Torres initially pleaded guilty with de officio counsel, while Federico Basas and Rolando Aunor (alias Rolando Amor/Anor) pleaded not guilty.
Subsequent developments included:

Withdrawal of the guilty pleas by Tobias Ribadajo, Romeo Corpuz, and Rodolfo Torres during the presentation of evidence.
Denials by accused Ribadajo and Corpuz regarding their participation, along with a repudiation of their confessions, which they claimed were extracted under duress.
Accused Basas and Torres eventually admitted to their confessions, while accused Rosendo Anor later changed his plea from not guilty to guilty of homicide (a lesser offense).

After the presentation of evidence and the confessions, the Trial Court rendered its decision on November 28, 1974.
The Court found Tobias Ribadajo, Romeo Corpuz, Federico Basas, Rosendo Anor, and Rodolfo Torres guilty beyond reasonable doubt for murder under Article 248 of the Revised Penal Code.
The convicted were sentenced to suffer the penalty of death, with additional orders for:

Indemnification of the victim’s heirs in the amount of ₱12,000.00 (later raised to ₱130,000.00).
Payment of moral and exemplary damages aggregating ₱20,000.00.
Sharing the proportionate costs of the proceedings.

Appellants, however, raised several grounds of appeal against the Trial Court’s decision, which will be further addressed in the Issues section.

Whether the Trial Court erred in admitting and giving substantial weight to the extrajudicial confessions of the accused.
Whether the accused’s claim that their confessions were extracted under coercion, including physical abuse and exposure to harsh conditions, warranted exclusion of such evidence.

Whether the Trial Court erred in determining that aggravating circumstances such as treachery, evident premeditation, and recidivism were present in the commission of the crime.
Whether the evidence sufficiently supported the finding of these aggravating circumstances given the manner and planning of the assault.

Whether convicting the accused for murder—and consequently imposing the death penalty—is legally sustainable.
Whether the imposition of the maximum penalty, even in the context of the accused serving sentences for previous convictions (recidivism), was appropriate based on the facts of the case.