Case Summary (G.R. No. L-32571-72)
Charges and Proceedings
The two accused were charged with separate informations, each for murder under the Revised Penal Code. They initially pleaded not guilty upon arraignment on September 14, 1970, with legal representation from Atty. Jose Galvan. However, shortly after, they withdrew their not guilty pleas and opted to plead guilty. The trial court informed them of the death penalty's potential consequences, yet they affirmed their new pleas of guilty, resulting in the immediate imposition of the death penalty.
Detailed Account of the Crime
The information provided details that both accused, along with others, conspired to attack members of a rival gang, the Sigue-Sigue Sputnik, during a melee in the prison. They utilized deadly weapons, leading to the fatal stabbings of Danao and Guevarra and injuries to six other inmates. Evidence from medical examinations confirmed the direct causation of death due to multiple stab wounds, substantiating the murder charges against Pajarillo and Rodriguez.
Acceptance of the Guilty Plea
The Court examined whether the trial court acted correctly in accepting the guilty pleas without additional evidence regarding the guilt and circumstances. It was noted that the accused were fully aware of the implications of their pleas, aided by counsel. The Solicitor General deemed the pleas as not improvident given the accused were cognizant of the capital punishment awaiting them and were represented throughout the process.
Mitigating and Aggravating Circumstances
The Court clarified that while both accused acknowledged their guilt, the presence of aggravating circumstances such as treachery and superior strength was not substantiated by evidence. It was found that these elements were not supported by the investigation reports nor by the testimonies, aligning with the defense's argument. Instead, it was recognized that Pajarillo's actions exhibited evident premeditation, while Rodriguez acted on impulse, which negated the continuum of applicable aggravating circumstances.
Reevaluation of Charges and Penalties
In light of the recognized mitigating circumstances—plea of guilty and voluntary surrender—the Court determined that Rodriguez should be charged with homicide instead of murder, while Pajarillo's actions warranted a murder conviction with evident premeditation. Consequently, the penalties were adjusted to imprisonment terms rather than death, with Pajarillo's penalty set between prision mayor and reclusion temporal, and Rodriguez’s between prision correccional and prision mayor.
Civil Liabilities
Both Pajarillo and Rodriguez contested the imposition of civil liabilities, specifically the moral and exemplary d
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Case Overview
- This case involves an automatic review by the Supreme Court of the Philippines concerning two decisions from the Circuit Criminal Court of Rizal.
- The accused, Juanito Pajarillo and Almario Rodriguez, were sentenced to death for the murders of Roque Danao and Reynaldo Guevarra.
- Each accused was ordered to indemnify the heirs of the deceased with P12,000, pay P5,000 for moral damages, P5,000 for exemplary damages, and cover proportionate costs.
Procedural History
- The accused were arraigned on September 14, 1970, represented by Atty. Jose Galvan, and initially pleaded not guilty.
- On the first day of trial (September 16 and 17, 1970), both accused requested to change their plea to guilty.
- The trial court informed them of the consequences of their plea, including the potential for a death sentence.
Facts of the Case
- The incidents in question occurred on December 6, 1969, at the Muntinlupa Penitentiary during a riot between rival gangs, BRM (Bicol Region Masbate) and Sigue-Sigue Sputnik.
- During the melee, both accused stabbed and killed inmates Roque Danao and Reynaldo Guevarra.
- The medical report indicated that both victims died from multiple stab wounds.
Legal Issues
- The Court questioned whether the trial court acted appropriately in accepting the guilty plea and imposing the death penalty without additional evidence.