Case Digest (G.R. No. L-46960-62)
Facts:
People of the Philippines v. Wilfredo Rojas, Teodoro Villarin, Solomon Totoy, Gregorio Tundag and Sinfroso Masong, G.R. No. L-46960-62, January 08, 1987, the Supreme Court En Banc, Per Curiam.On the morning of May 23, 1973, three girls—Zenaida Nastae (21), Canda Carluman (7) and Mona Carluman (5)—were killed at the seashore in Digon, Margosatubig, Zamboanga del Sur; two of the victims had their ears severed. The following day a joint PC‑police posse arrested seven persons in Barrio Talanusa (including Teodoro Villarin, Saturnino Totoy, Solomon Totoy, Gregorio Tundag, Sinfroso Masong, Mohamod Esmael, and Balbino Estrera), and later Wilfredo Rojas was arrested in Malangas; items seized included firearms, knives, bottles of oil (an “anting‑anting”), clothing, and two human ears.
After investigation, the suspects were charged in three informations; Esmael and Estrera were discharged from criminal liability and permitted to testify as state witnesses. The remaining accused were given counsel de oficio. An extended trial resulted in a January 27, 1975 judgment convicting the accused of three counts of murder and sentencing them to death; Saturnino Totoy alone received a lesser penalty because of minority. The trial court found conspiracy, treachery, cuadrilla (band), dwelling and evident premeditation as aggravating circumstances and imposed civil indemnities.
Because death sentences were imposed, the case was brought to the Supreme Court on automatic review. The accused raised factual and legal challenges, including (a) that there was no conspiracy; (b) that the death penalty could not be imposed collectively on all conspirators; (c) that certain aggravating circumstances (cuadrilla, dwelling, evide...(Pro-only)
Issues:
- Was the trial court’s finding of conspiracy among the accused supported by the evidence?
- May each conspirator be held equally liable and be sentenced to death for the murders committed by one or more co‑conspirators?
- Were the aggravating circumstances of cuadrilla (band), dwelling, evident premeditation and cruelty properly applied?
- Was Solomon Totoy’s extrajudicial confession admissible under Article I...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)