Case Digest (G.R. No. L-35969)
Facts:
People of the Philippines v. Celestino Villacores, Romulo Lirio, Pedro Ducay and Abis Gamongan, G.R. No. L-35969. May 16, 1980, the Supreme Court En Banc, Antonio, J., writing for the Court. Automatic review of the judgment of the Circuit Criminal Court, Pasig, Rizal, which had convicted the four appellants of murder and multiple frustrated murder and imposed the penalty of death.The Special Prosecutor filed an Information on October 10, 1972, charging that on or about May 4, 1972 at the New Bilibid Prison (NBP), Muntinlupa, the four accused, then confined there, conspired and stabbed several fellow prisoners; one victim, Romeo Domingo, later died. At arraignment on October 27, 1972, the four, with court‑appointed counsel, pleaded guilty after the court informed them in Tagalog of the consequences; the trial court accepted the pleas, found them guilty under Article 248 (murder) of the Revised Penal Code and sentenced them to death with awards of civil indemnity, moral and exemplary damages.
Noting the capital nature of the offense, the trial court nevertheless ordered the Special Prosecutor to present evidence "to determine the degree of culpability of the accused" (citing People v. Epifanio Flores). The prosecution produced testimonial, documentary and medico‑legal evidence on October 28 and December 9, 1972, including extrajudicial confessions by the appellants (admitted without objection), the weapons they surrendered, and the autopsy report establishing a fatal stab wound. After the prosecution rested, the trial court affirmed the death sentences and transmitted the records for automatic review by this Court.
Appellants' counsel contended that the guilty pleas were improvident because the ...(Subscriber-Only)
Issues:
- Was the plea of guilty by the appellants to capital offenses valid and knowingly made?
- Were the extrajudicial confessions obtained without counsel prior to January 17, 1973 admissible in evidence?
- Did the prosecution’s evidence establish the elements and aggravating circumstances (conspiracy, evident premeditation, treachery) necessary to sustain murder convictions and justify the maximum penalty?
- Did the trial court’s premature pronouncement of sentence (before taking prosecution evidence) warr...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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