Title
People vs. Dela Cruz
Case
G.R. No. L-46397
Decision Date
May 16, 1983
Defendants, inmates in New Bilibid Prison, conspired to kill a rival gang member, pleaded guilty, and were convicted of murder. The Supreme Court reduced their death penalty to life imprisonment, citing subhuman prison conditions as a mitigating factor.
murder
death penalty
reclusion perpetua

Case Summary (G.R. No. L-46397)

Factual Background

The trial court’s factual findings, as quoted in the decision and described as uncontroverted by the appellants, stated that all accused were confined at Brigade I-D prior to March 8, 1976. They were able to get out from the brigade after planning to kill someone belonging to the GIG gang. The record characterized all accused as members of the Bahala Na Gang, with the motive traced to the death of one among them at the hands of the GIG gang.

All accused were charged with murder for the stabbing of Mabini Garachico. In the trial proceedings, each accused entered a plea of guilty upon arraignment. The decision noted that, during arraignment, they were fully apprised of the consequences of a plea of guilty, and the trial court proceeded with the required presentation of evidence to establish the circumstances of the crime. The evidence presented by the prosecution centered on extra-judicial confessions attributed to the accused, each marked as exhibits, and supported by medical and documentary evidence.

The prosecution presented extra-judicial confessions marked as Exhibits A to A-2 for Antonio dela Cruz, which included an apprisal of constitutional rights, including the right to remain silent and the right to be assisted by counsel, and contained admissions that he stabbed the victim at about 5:45 P.M., together with other identified prisoners. Specifically, the exhibits narrated stabbing with Boy Bakal later identified as Virgilio Baluyot; with Boy Deo later identified as Hernando Deo; and with Bicol later to be identified by Edgardo Marino as Reynaldo Arnaldo. For Hernando Deo, the record referred to Exhibit B (and portions thereof B-1 and B-2) that included compliance with constitutional rights and an admission that, on March 8, 1976, while at Brigade I-D during evening food service, they escaped when the brigade keeper opened the door, enabling the accused to leave armed with improvised weapons, and that the gate being padlocked occurred after Deo was already outside and went to attack the victim.

For Edgardo Marino, the prosecution presented Exhibit C, including a portion C-1 on constitutional rights, a portion C-2 on admission of participation, and Exhibit C-4 on the improvised weapon he allegedly used. A similar treatment was described for Virgilio Baluyot, whose confession was marked as Exhibit D, with reference to a plan to kill and to the victim’s resulting death. The record stated that the victim, described as 29 years old, died of hemorrhage, acute massive, secondary to stab wounds. The prosecution also presented a sketch of a weapon that was said to fit the actual weapon upon fitting, supported by the correspondence between sketches and weapons through specified exhibits. In addition to the prosecution’s testimonial and confession evidence, the prosecution produced a necropsy report and a death certificate, Exhibit F, for Mabini Garachico.

Trial Court Proceedings

The trial court, acting under the relevant rules on pleas of guilty, accepted that the accused had pleaded guilty, after being assisted by counsel. The decision emphasized that the trial court required the prosecution to present evidence to show the circumstances under which the crime had been committed. It explained that this necessity was anchored on the doctrine laid down by the Supreme Court in Ricalde vs. Villaluz and in Epifanio Flores.

After receiving the prosecution evidence, the trial court found the accused guilty of murder and imposed the supreme penalty of death on each, together with awards to the heirs and for moral and exemplary damages, and costs. The factual framework supporting the conviction relied on the extrajudicial confessions and corroborative proof discussed in the decision.

The Appellants’ Position on Appeal

On appeal, the appellants did not present any assignment of error. The decision stated that counsel de oficio had recounted that she personally interviewed the appellants in their prison cells in an effort to find a legal defense but was unable to do so. She also expressed appreciation for the trial judge’s conduct in personally examining the accused and giving them the opportunity to ventilate perceived injustices and pressures tied to the execution of their confessions and their plea of guilty. The concluding paragraph of the appellants’ brief, as quoted, reflected that no legal defense could be raised because the facts were said to be true and due process denial could not be claimed; counsel instead urged mercy, including reference to conditions in the penitentiary.

The Court’s Assessment of Criminal Liability

The reviewing Court declared that the crime shown beyond reasonable doubt by the evidence was murder, and it treated the trial court’s factual findings as having support in the record described. It also addressed the circumstance that the killing occurred inside the New Bilibid Prison, where the accused were serving sentences for other offenses. It was further noted that all appellants except Edgardo Marino were described as death convicts at the time relevant to penalty.

On that basis, the Court held that the trial court correctly imposed the death penalty, citing Article 160 of the Revised Penal Code, given the status of the accused and the applicable legal consequences for murder under the conditions discussed.

Modification of the Penalty

Despite affirming guilt and the general penalty scheme, the Supreme Court modified the sentence. It held that, considering “the circumstances under which the offense was perpetrated” in the light of the “deplorable condition” existing in the national penitentiary—conditions previously taken cognizance of by the Court in People vs. delos Santos and People

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