Case Summary (G.R. No. L-46397)
Overview of Charges and Guilty Pleas
The defendants were charged with murder for the killing of victim Mabini Garachico on March 8, 1976. During the arraignment, they entered a plea of guilty after being duly informed by the trial court of the implications of their confession. Following their guilty plea and under the ruling in Ricalde vs. Villaluz, evidence of the circumstances surrounding the crime was presented by the prosecution, necessitating a factual exploration beyond the mere plea.
Details of the Crime
The trial court established that the defendants were members of the Bahala Na Gang and had conspired to kill members of a rival gang, GIG, after one of their own was killed. On the date of the incident, they allegedly plotted and executed the stabbing of Garachico while armed with improvised weapons during evening meal service in the prison, leading to his death due to stab wounds.
Presentation of Evidence
The prosecution produced various extrajudicial confessions from the accused, which were supported by physical evidence, including the weapons used in the crime and a necropsy report confirming Garachico's cause of death as hemorrhage resulting from stab wounds. The defendants, in their confessions, acknowledged their involvement and the circumstances of the crime.
Defense and Legal Arguments
The defendants did not contest the facts but rather their legal counsel expressed that no defenses could be provided due to the absence of errors by the trial court. The defense focused on the harsh conditions of the penitentiary, which they argued contributed to the situation that led to the crime, effectively pleading for mercy rather than contesting the conviction.
Penalty Imposition
Despite the factual proofs establishing murder beyond a reasonable doubt and the recidivist status of the defendants, the trial court’s initial decree of death penalty was scrutinized. The Supreme Court noted that all but one of the appellants were already on death row, thus altering the sentence to reclusion perpetua due to mitigating factors related to the conditions in the national penitentiary and
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Court and Case Information
- Court: Supreme Court of the Philippines
- Decision Date: May 16, 1983
- Case Number: G.R. No. L-46397
- Lower Court: Circuit Criminal Court of Rizal
- Case Title: PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ANTONIO DELA CRUZ, HERNANDO DEO, REYNALDO ARNALDO, VIRGILIO BALUYOT AND EDGARDO MARINO, DEFENDANTS-APPELLANTS
Background of the Case
- The case involves a review of the decision rendered by the Circuit Criminal Court of Rizal in Criminal Case No. CCC-VII-1884.
- The defendants-appellants were found guilty of murder and sentenced to death, along with financial penalties for the heirs of the victim and additional damages.
- The defendants, upon arraignment, pleaded guilty after being informed of the consequences of their plea.
Facts of the Case
- The defendants are Antonio dela Cruz, Hernando Deo, Reynaldo Arnaldo, Virgilio Baluyot, and Edgardo Marino.
- They were charged with murder for the killing of Mabini Garachico on March 8, 1976, inside the New Bilibid Prison, Muntinlupa, Metro Manila.
- The charge included allegations of conspiracy, use of deadly weapons, intent to kill, treachery, and evident premeditation.
- The accused were deemed recidivist-habitual delinquents, having committed the crime while serving a sentence