G.R. No. L-48642 - People vs. Salcedo

The incident occurred inside the National Penitentiary (New Bilibid Prison) in Muntinlupa, Metro Manila.
The conflict arose between two rival prison gangs: the Sigue-Sigue Sputnik gang (accused) and the Genuine Ilocano Gang (G.I.G.), whose members were serving sentences in different dormitories.
The accused were confined in Brigade Dormitory No. 4-D while the victims belonged to Brigade Dormitory No. 13 and were assigned as kitchen boys tasked with delivering breakfast rations.

On the morning of September 24, 1975, at approximately 10:00 o’clock, six kitchen boys were delivering breakfast near Dormitory No. 4-D when the incident unfolded.
Members of the Sigue-Sigue Sputnik gang, under the command of their leader Generoso Dungca (alias "Boy Kamatis"), suddenly rushed out armed with improvised deadly weapons, including a spear, ice picks, and darts, and attacked the kitchen boys.
In the melee that ensued, one of the victims, Cirilo Monroy, sustained multiple stab wounds resulting in fatal hemorrhage, while the others suffered serious stab wounds that could have been fatal without timely medical intervention.
Emergency intervention by prison guards restored order, and the wounded were rushed to NBP Hospital for treatment.

The incident was investigated, leading to the identification and charging of the attackers with Murder and Multiple Frustrated Murder.
The information was filed by the Provincial Fiscal of Rizal on February 3, 1977, naming Generoso Dungca, Tomas Salcedo, Roberto Esguerra, Roberto Madayao, and Alberto Leban.
On February 10, 1977, Tomas Salcedo, Roberto Esguerra, Roberto Madayao, and Alberto Leban were arraigned; Salcedo pleaded guilty while the others pleaded not guilty.
Generoso Dungca, the acknowledged leader behind the attack, was not arraigned due to his escape from prison on April 23, 1976, and remained at large.

After a full trial, the trial court rendered its decision on August 30, 1977.
The accused were found guilty beyond reasonable doubt of the crimes charged.
For the charge connected to the death of Cirilo Monroy, the defendants were sentenced to death, ordered to indemnify the victim’s heirs, and pay moral and exemplary damages.
Regarding the charge of Multiple Frustrated Murder, the sentence prescribed reclusion temporal with a term ranging from seventeen years, four months, and one day to twenty years, along with corresponding damages and cost awards.
The decision was automatically elevated to the Supreme Court for review because it imposed the death penalty.

The appellate review was conducted without a reply brief from the appellants, and the trial court’s evidentiary findings were largely upheld.
The sole assignment of error from the appellants argued that the trial court had failed to establish the crimes with clear and convincing evidence beyond reasonable doubt.
The court reviewed and dismissed the self-defense narrative advanced by the accused, noting that there was no evidence that the victims were armed.
Additional evidence, such as the recovery of weapons near key locations and the absence of injuries among the accused compared to the serious injuries of the victims, reinforced the trial court’s findings.
Roberto Esguerra died in prison on January 8, 1981, leading to a separate dismissal of the case against him with respect to his criminal liability.

Whether the trial court established, beyond a reasonable doubt, that the accused were the aggressors in the premeditated attack.
Whether the evidence sufficiently demonstrated the elements of murder and multiple frustrated murder, including treachery, evident premeditation, and recidivism.

Whether the accused’s assertion of self-defense was credible given the circumstances, notably the unarmed state of the victims.
The validity of the defendants’ claim that the altercation originated from a personal dispute between Tomas Salcedo and Cirilo Monroy, culminating in self-defense.

Whether the trial court erred in imposing the death penalty, and if such a sentence was proper under the circumstances.
The appropriateness of the dismissal of criminal charges against Roberto Esguerra due to his death and the subsequent treatment of his civil liabilities.
Whether the additional award of indemnity (increased to P30,000.00) was justified in light of the evidence and legal standards.