Facts:

The case at hand is G.R. No. L-40294, decided on July 11, 1986, involving the People of the Philippines as the plaintiff-appellee against defendants-appellants Tobias Ribadajo, Romeo Corpuz, Federico Basas, Rosendo Anor, and Rodolfo Torres. The case originated from the Circuit Criminal Court of Pasig, Rizal, where the defendants were charged with murder in Criminal Case No. CCC-VII-1329-Rizal. The incident occurred on November 18, 1971, at approximately 7:55 PM, within the confines of the New Bilibid Prison in Muntinlupa, Rizal. The defendants, all inmates, executed a plan to attack members of a rival group, Brigade 3-A, in retaliation for previous mockery and humiliation they had suffered. They used a false key to open their dormitory door and ambushed the victim, Bernardo Cutamora, while he was collecting his food ration. The attack resulted in multiple stab wounds, leading to Cutamora's death, as confirmed by a necropsy report. Following the incident, the defendants co...

Facts:

1. Incident Overview: On November 18, 1971, at around 7:55 PM, inmates from Brigade 3-C of the New Bilibid Prison in Muntinlupa, Rizal, used a false key (made from a tin can) to open their dormitory door. They attacked inmates from Brigade 3-A, who were receiving their food rations. The victim, Bernardo Cutamora, was stabbed multiple times by the accused, resulting in his death.

2. Planning and Motive: The accused, led by Tobias Ribadajo, planned the attack earlier that day at around 1:00 PM. Their motive was to avenge being mocked and having human waste thrown at them by inmates from Brigade 3-A, who were members of the OXO gang.

3. Confessions and Investigation: On November 20, 1971, all accused executed statements admitting their participation in the killing. These confessions were detailed and included nicknames of co-accused, which only they could have known.

4. Legal Proceedings: An Information for Murder was filed on April 24, 1973. During arraignment, some accused pleaded guilty, while others pleaded not guilty. Later, some withdrew their guilty pleas, claiming their confessions were obtained under duress. The Trial Court found all accused guilty of Murder and sentenced them to death.

5. Appeal Arguments: The appellants argued that their confessions were coerced, that the aggravating circumstances of treachery, evident premeditation, and recidivism were improperly applied, and that they should only be convicted of Homicide or "Death Caused in a Tumultuous Affray."

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Voluntariness of Confessions: The Court held that the confessions were voluntary and admissible. The presumption of law favors the spontaneity and voluntariness of extrajudicial confessions. The accused failed to provide concrete evidence of duress or coercion.

2. Aggravating Circumstances:

   • Treachery: The attack was sudden and unexpected, and the victim was unarmed and unable to defend himself.
   • Evident Premeditation: The plan to kill was hatched hours before the execution, and the accused had ample time to desist but did not.
   • Recidivism: All accused were serving sentences for prior crimes under the same Title of the Revised Penal Code.

3. Conviction and Penalty: The Court found no error in the Trial Court's imposition of the death penalty under Article 248 of the Revised Penal Code. However, due to the lack of necessary votes, the penalty was reduced to reclusion perpetua.

4. Defense Arguments Rejected: The defense's claim that the incident was a "tumultuous affray" was rejected, as there was no reciprocal aggression or confusion. The attack was a coordinated effort by the accused against the victim.

Separate Opinion

Chief Justice Teehankee concurred with the result but maintained his dissenting view in previous cases regarding the retroactive application of the right to counsel during custodial investigations. He argued that the right to counsel was statutorily mandated as early as 1954 under Republic Act 1083, which amended Article 125 of the Revised Penal Code.