Case Summary (G.R. No. 196355)
Incident Description
On July 26, 1972, at approximately 7:00 to 8:00 PM, Rodolfo Ibanez was repeatedly stabbed, suffering a total of sixteen stab wounds and six incised wounds, eight of which were lethal. He succumbed to his injuries upon his arrival at a hospital. Following the attack, prison investigator reports indicated that Atienza initiated the assault, and he was joined by four accomplices: Tomas Sarmiento, Ignacio Barraca, Jr., Alfredo Regular, and Benito Pablatin. However, Atienza was the only one who surrendered to the authorities post-incident.
Motive and Confession
Atienza claimed that the assault was motivated by a sense of vengeance; he asserted that Ibanez had previously killed one of his fellow inmates, Alfredo Mariano. In his extrajudicial confession, Atienza stated that he acted in self-defense, alleging that Ibanez had attempted to persuade him to join in an attack against members of a rival gang and was about to pull out a weapon. He acknowledged that when Ibanez allegedly made this move, he stabbed Ibanez in the chest and continued to attack him.
Trial Proceedings
In the trial, Atienza initially pleaded not guilty but later changed his plea to guilty after the prosecution began presenting evidence. He maintained that he acted alone and denied the involvement of the other four prisoners, which the trial court accepted. This led to the acquittal of the four companions of Atienza.
Court Findings and Conviction
The trial court ultimately convicted Atienza of murder, aggravating the crime by treachery and evident premeditation, resulting in the imposition of the death penalty. The court also mandated Atienza to provide indemnity to the heirs of Ibanez amounting to twenty thousand pesos. Following the conviction, the case was automatically reviewed by the Supreme Court, where legal arguments focused on the classification of the crime and the propriety of the imposed penalty.
Assessment of Self-Defense Claim
The Supreme Court evaluated Atienza's claim of self-defense, concluding that this argument was not tenable since no weapon was found on Ibanez. The court noted the inconsistency in Atienza's defense since he had previously entered a guilty plea after acknowledging the charges against him. Furthermore, the Solicitor General indicated that the offense committed by Atienza was more appropriately classified as homicide rather than murder, as the aggravating factors initially cited—treachery and premeditation—did not apply.
Reevaluation of Charges and Sentencing
The Supreme Court ruled that recidivism, which typically enhances penalties, could not be considered in this instance as Atienza's prior crimes involved offenses against property, wherea
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Case Background
- The case involves a convict-against-convict killing that occurred in the New Bilibid Prison, where prisoners often engaged in violent feuds.
- On the night of July 26, 1972, Rodolfo Ibanez, a 22-year-old prisoner, was repeatedly stabbed in a corridor near cell 2 of dormitory 4-A-2.
- Ibanez suffered a total of 16 stab wounds and 6 incised wounds, with 8 of the wounds being fatal, affecting his internal organs.
- He died shortly after arriving at the hospital.
Incident Details
- Amador Atienza was identified as the primary assailant who initiated the attack on Ibanez.
- Four other prisoners, Tomas Sarmiento, Ignacio Barraca, Jr., Alfredo Regular, and Benito Pablatin, allegedly collaborated in the assault.
- Atienza was the only assailant who surrendered to the prison guard after the incident.
- The motive for the attack stemmed from a desire for vengeance for the death of Alfredo Mariano, a prisoner killed by Ibanez in September 1971.
Atienza's Confession and Defense
- Atienza, serving a sentence for attempted robbery with homicide, confessed that he stabbed Ibanez after Ibanez suggested they jointly attack members of the rival Bahala Na Gang.
- Atienza claimed he acted in self-defense, stating that Ibanez was about to pull out a weapon, leading him to stab Ibanez first.
- In his extrajudicial confession, Atienza admitted to stabbing