Case Summary (G.R. No. 210043)
Incident Overview
On March 28, 1971, Lachica and Sigador fatally attacked Dominador Aguilar inside his cell at Dormitory 1-C, resulting in his death from multiple stab wounds, as confirmed by an autopsy performed by Dr. Rodulfo Soratos of the National Bureau of Investigation (NBI). After the attack, both accused admitted their roles to prison guards and willingly surrendered the knives used in the stabbing.
Confession and Trial Proceedings
During police investigation, both accused provided statements wherein Lachica outlined the premeditated nature of the crime, asserting Aguilar as the mastermind behind a prior attack on them. They were charged with murder and, represented by appointed counsel Atty. Jose O. Galvan, pleaded guilty upon arraignment. Following their plea, the trial court held a separate hearing to determine the degree of culpability and established that their actions exhibited treachery and evident premeditation.
Defense Claim and Self-Defense Argument
In their defense, Lachica claimed that he acted in self-defense due to a perceived threat from Aguilar. He alleged that Aguilar threatened his life, prompting him to strike first. However, the court determined that mere intimidating words from an unarmed individual did not constitute unlawful aggression necessary for a self-defense claim, thereby undermining their argument.
Court Findings and Sentencing
The court concluded that the confessions were substantive evidence of guilt, particularly given that Lachica did not contest the statement in subsequent proceedings. The lower court recognized quasi-recidivism as a significant aggravating factor due to Lachica's prior convictions. Initially, the death penalty was imposed; however, owing to a lack of consensus among the justices, it was ultimately commuted to reclusion perpetua.
Indemnification Order
In addition to the modified sentence, the court ordered Lachica and Sigador to indemnify the heirs of the victim, Dominador Aguilar, in the amount of ₱30,000 as compensation for the loss suffered by the victim's family.
Judicial Consen
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Case Syllabus (G.R. No. 210043)
Case Background
- The case involves the conviction of Romeo Lachica and Jilly Sigador for the crime of murder, which took place within the confines of the New Bilibid Prison in Muntinglupa.
- Both accused were serving sentences for other crimes at the time of the incident; Lachica was awaiting review of two death penalties for double murder and double frustrated murder, while Sigador was awaiting execution for a prior sentence.
- The case has become moot for Sigador, who was executed on June 26, 1974, under a previous ruling.
Incident Details
- On the morning of March 28, 1971, Dominador Aguilar, a fellow inmate, was stabbed to death by Lachica and Sigador inside his cell in Dormitory 1-C.
- The autopsy conducted by Dr. Rodulfo Soratos revealed that Aguilar sustained eight stab wounds, with the most serious injuring the left lung and perforating the heart.
- After the attack, both accused voluntarily surrendered to a prison guard, Baldovino, and admitted to using knives in the assault.
Confession and Arraignment
- Both accused provided statements to the investigation officers, detailing their involvement in th