Case Summary (G.R. No. L-38346-47)
Facts of the Case and Crime Committed
On September 12, 1972, Abarca and Dioso sought to avenge the killing of their gangmate, Balerio, whom they believed was slain by members of the rival gang. Abarca feigned illness to gain admission to the prison hospital ward where both victims were confined. Upon locating Reyno and Gomez, the accused suddenly attacked them with improvised knives, stabbing both to death. The victims died from massive bleeding caused by multiple stab wounds to the chest and abdomen. Immediately after the attack, Dioso and Abarca surrendered to prison guard Enriquito Aguilar and voluntarily handed over their weapons.
Confessions and Admission of Guilt
Both accused readily confessed to the crime during interrogation by prison investigator Buenaventura dela Cuesta, providing detailed sworn statements. Dioso described how he stabbed Reyno and assisted Abarca in stabbing Gomez, while Abarca narrated the sequence of events from his perspective. Both acknowledged their intent to kill as retaliation for Balerio’s murder by rival gang members and admitted to the sudden nature of the attack within the hospital ward.
Trial Proceedings and Plea
Upon arraignment, Dioso and Abarca voluntarily pleaded guilty to the charge of murder. The trial court proceeded to examine evidence to determine the degree of culpability. The accused acknowledged the voluntariness of their confessions. The trial court found that the crime was committed with alevosia, as the victims were in vulnerable positions, incapable of defending themselves due to the element of surprise and their physical condition—one was having breakfast, the other lying under a mosquito net.
Legal Analysis and Application of the Law
The court noted the absence of any challenge by the accused to the trial court's findings of guilt. The appellants appealed only to mitigate the sentence by invoking the circumstances of voluntary surrender and their guilty plea. However, under the applicable law at that time, the accused were considered quasi-recidivists, having committed murder while already serving sentences for prior offenses. According to Article 160 of the Revised Penal Code and prevailing jurisprudence, such status mandates the imposition of the maximum penalty presc
...continue readingCase Syllabus (G.R. No. L-38346-47)
Background and Nature of the Case
- This case involves the mandatory review of death sentences handed down by the Circuit Criminal Court of Rizal against Teofilo Dioso and Jacinto Abarca.
- Both accused were convicted for the crime of murder committed inside the New Bilibid Prison, located in Muntinlupa, Rizal.
- At the time, Abarca was already serving a sentence for homicide, and Dioso was sentenced for robbery.
- The crime took place within the prison environment, highlighting issues of inmate gang conflicts and prison security.
Parties and Affiliations
- The accused, Teofilo Dioso and Jacinto Abarca, were members of the "Batang Mindanao" gang within the prison.
- The victims, Angelito Reyno and Fernando Gomez, were prisoners allied with the rival "Happy Go Lucky" gang.
- The two gangs had a history of intermittent and at times violent clashes inside the facility.
- The incident in question followed the death of Balerio, a member of "Batang Mindanao," which was attributed to members of the "Happy Go Lucky" gang.
Facts Surrounding the Crime
- On September 12, 1972, at approximately 6:15 a.m., Abarca feigned illness and sought admission to the hospital within the prison, accompanied by Dioso.
- Upon entering Ward 6, they located the intended victims: Reyno consuming breakfast and Gomez lying on a wooden bed ("tarima") under a mosquito net.
- Dioso approached Reyno and engaged him briefly in conversation while Abarca advanced toward Gomez.
- Suddenly, both drew improvised knives ("matalas"), with Abarca lifting the mosquito net and stabbing Gomez, while Dioso simultaneously attacked Reyno with similar weapons.
- Following Reyno’s collapse, Dioso assisted Abarca in inflicting further injuries on Gomez.
- Upon exiting Ward 6, they encountered Prison Guard Enriquito Aguilar and voluntarily surrendered their weapons.
- The medico-legal officer, Dr. Ricardo E. Baryola, confirmed that both victims died from multiple stab wounds to the chest and abdomen causing massive bleeding.
Confessions and Admissions of Guilt
- Both accused were immediately interrogated by prison investigator Buenaventura dela Cuesta and voluntarily executed sworn statements admitting responsibility.
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