Case Summary (G.R. No. L-15307)
Facts of the Case
On February 16, 1958, a fight erupted between rival gangs inside the National Penitentiary. The "Sigue-sigue" gang, comprised of Manila boys, and the "OXO" gang, composed of Visayans and Ilocanos, faced off during this altercation. Following the conflict, members of the "OXO" gang, including Duenas, Tobias, and Mainar, conspired to retaliate against the "Sigue-sigue" gang. The following day, they attempted to gain access to Brigade 3-A, occupied by the "Sigue-sigue" gang, with the intent to exact revenge.
Incident and Actions
On February 17, 1958, Duenas, accompanied by de los Reyes, approached the door of Brigade 3-A. There, Gonzales assaulted de los Reyes with a piece of wood, causing him to fall. Tobias then fatally stabbed de los Reyes. The situation escalated as members of the "OXO" gang shouted for revenge against the "Sigue-sigue" gang, indicating their prior agreement to harm their enemies.
Evidence Presented
The prosecution’s evidence included eyewitness testimonies asserting that Duenas, Gonzales, and Tobias directly engaged in the assault on de los Reyes. The victim suffered multiple fatal wounds including strangulation and stab wounds. The defense, however, denied the involvement of Duenas, Gonzales, and Tobias, each presenting alibis claiming they were not present at the time of the incident.
Conspiracy and Criminal Liability
The court established that there existed a conspiracy among the appellants to retaliate against the "Sigue-sigue" gang. The actions taken were premeditated, with the preparation of weapons and the gathering of members, all serving to support the claim of collective criminal responsibility. Despite some acquitted parties' claims of innocence, the evidence against the primary accused remained compelling.
Court’s Findings and Conclusion
Due to the nature of the assault, which was sudden and deadly, the court found the murder to be qualified by treachery, as there
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Case Overview
- The case involves a review of the judgment from the Court of First Instance of Rizal.
- The appellants, Constantino Duenas, Felipe Gonzales, Juanito Tobias, Angel Flores, Sofronio Dagami, Pablo Roxas, and Custodio Mainar (alias "Inchik"), were found guilty of murder.
- Each appellant was sentenced to death and ordered to pay the heirs of the victim, Carlos de los Reyes, P6,000.00, along with their share of the costs.
Incident Background
- The incident occurred on February 17, 1958, amidst fighting between two rival inmate gangs at the National Penitentiary in Muntinglupa: the "Sigue-sigue" gang (Manila boys) and the "OXO" gang (Visayans and Ilocanos).
- The "Sigue-sigue" gang occupied Brigade 3-A, while the "OXO" gang was in Brigade 3-D, leading to tensions and preparations for retaliation.
Events Leading to the Murder
- Early on February 17, inmate Dionisio Valdez was persuaded by members of the "OXO" gang, including Duenas and Tobias, to help break into Brigade 3-A.
- Upon reaching Brigade 3-A, they discovered it was locked and could not enter.
- Concurrently, Nataniel Labampa attempted to enter Brigade 3-A but was similarly denied access.