Facts:

The case involves Generoso N. Subayco, Alfredo T. Alcalde, and Eleuterio O. IbaAez as petitioners against the Sandiganbayan and the People of the Philippines as respondents. The events transpired during a significant protest rally known as the "Welga ng Bayan" held on September 20, 1985, in Escalante, Negros Occidental, against the Marcos government, which was nearing its end. The rally, attended by thousands, was marked by a heavy military presence and ended tragically when military and para-military forces opened fire on the demonstrators, resulting in the deaths of twenty individuals and injuries to twenty-four others. Following the incident, multiple counts of murder and frustrated murder were filed against several individuals, including the petitioners, who were part of the police-military group responsible for the dispersal operation. The Sandiganbayan conducted a trial, ultimately convicting Subayco, Alcalde, and IbaAez while acquitting the other accused. The...

Facts:

Background of the Incident

• The case arose from the tragic events of September 20, 1985, during the "Welga ng Bayan" (People's Strike) in Escalante, Negros Occidental.
• The rally was organized to protest against the Marcos regime, coinciding with the 13th anniversary of the declaration of martial law.
• The rally turned violent when military and para-military forces opened fire on the demonstrators, resulting in the death of 20 individuals and injuries to 24 others.

Charges and Accused

• Multiple counts of murder and frustrated murder were filed against 45 individuals, including civilian government officials, members of the Philippine Constabulary, Integrated National Police, and the Civilian Home Defense Force (CHDF).
• Only 28 of the accused were arrested and tried, while the others remained at large.
• After trial, the Sandiganbayan acquitted most of the accused but convicted three individuals: Generoso N. Subayco, Alfredo T. Alcalde, and Eleuterio O. Ibañez.

Key Events During the Rally

• The rally began on September 18, 1985, and was attended by thousands of demonstrators.
• The demonstrators blocked the national highway, leading to tensions with authorities.
• On September 20, 1985, the authorities attempted to disperse the crowd using water cannons and tear gas.
• A single gunshot was fired, followed by a barrage of gunfire from multiple directions, resulting in the deaths and injuries of the demonstrators.

Evidence Presented

• Witnesses testified that the gunfire came from the Cadiz City firetruck and a "weapons carrier" used by the authorities.
• Seventy-nine empty shells were recovered from the scene, traced to firearms issued to some of the accused.
• The Sandiganbayan found that the petitioners and their companions fired indiscriminately at the demonstrators, leading to the casualties.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Implied Conspiracy:

   • Conspiracy does not require explicit agreement but can be inferred from the coordinated actions of the accused.
   • The petitioners' simultaneous and indiscriminate firing at the demonstrators indicated a shared criminal intent.
   • The Court cited People vs. Guevarra, which established that implied conspiracy arises when individuals act in unison to achieve a common criminal objective.

2. Right to Peaceful Assembly:

   • The Court reiterated the constitutional right of the people to assemble peacefully and petition the government for redress of grievances.
   • The use of deadly force to disperse a peaceful assembly is a grave violation of this right.
   • The Court referenced US vs. Apurado, which emphasized that disorderly conduct by individuals in a crowd should not be used to justify the suppression of peaceful assemblies.

3. Justice for the Victims:

   • The Court noted that justice would remain incomplete until all accused, including those still at large, are arrested and tried.
   • The Court directed the Secretary of Justice and the Secretary of Interior and Local Government to expedite the arrest of the remaining accused.

Conclusion:

• The Supreme Court affirmed the Sandiganbayan's decision, holding the petitioners liable for the deaths and injuries resulting from the Escalante massacre.
• The Court underscored the importance of upholding constitutional rights and ensuring accountability for abuses of power by authorities.