Case Summary (G.R. No. L-19069)
Key Dates and Applicable Law
Decision Date: October 29, 1968
Constitution: 1935 Philippine Constitution
Penal Statutes: Revised Penal Code (Common-Design Conspiracy, Murder provisions, Quasi-Recidivism aggravation)
Facts of the Bilibid Prison Riot and Murders
On February 16, 1958, rival inmates of two gangs (“Sigue-Sigue” predominantly Tagalog and “OXO” predominantly Visayan/Mindanao) clashed during Sunday mass preparations. After an initial fight in the plaza and a thwarted incursion by the Sigue-Sigue from Building 1 into Building 4, members of the OXO in Brigade 4-A forcibly broke locks of adjacent brigades (4-B, 4-C, 4-D) and systematically isolated and killed three Tagalog inmates: Carriego in 4-B, then Barbosa and Cruz in 4-C and near a fire escape. All victims died of multiple stab and club wounds.
Procedural History
• Information filed for multiple murder with aggravating circumstances against 22 inmates; six (including the six respondents) survived pre-trial and trial dismissals and acquittals.
• Lower court convicted Peralta, Factora, Dosal, Parumog, Larita, Luna of murder with treachery, band, superior strength, and other aggravations, sentencing each to death and indemnity.
• Parties appealed via automatic review.
Eyewitness Testimony and Identification
Successive inmate witnesses (Pineda, Marayoc, Sauza, Fontillas, Pabarlan, Halili, Espino) consistently identified Factora, Peralta, Dosal, Parumog, Larita, Luna as armed aggressors who clubbed and stabbed the three victims while victims were defenseless or pleading for mercy. Physical injuries and medical testimony confirmed multiple fatal wounds.
Defendants’ Invoked Defenses
• Peralta and Dosal claimed self-defense, alleging initial attacks by victims.
• Parumog, Larita, Luna asserted alibi, stating they were under investigation or remained in their cells throughout the riot.
Trial court found these defenses unworthy of belief given strong, consistent eyewitness identification and lack of documentary evidence for alibi detentions.
Aggravating Circumstances and Absence of Extenuation
Aggravations: quasi-recidivism (all serving prior sentences), treachery, band, armed persons, superior strength, insult to public authority.
No extenuating circumstance proved or alleged. Under Article 160 RPC, maximum penalties apply to quasi-recidivists.
Existence and Significance of Conspiracy
Although no overt prior meeting was shown, the deliberate selection and sequential killing of victims of one gang by members of another, armed preparation, and coordinated movement among brigades demonstrate an implied conspiracy. Conspiracy here is inferred from:
- Targeting only Tagalog inmates known as Sigue-Sigue;
- Collective arming and synchronized incursions;
- Participation of the same defendants in each killing.
Doctrine on Conspiracy and Collective Liability
• Conspiracy (Art. 8 RPC) is not itself punishable but, once crime is committed, renders all conspirators co-principals.
• All con
Case Syllabus (G.R. No. L-19069)
Procedural Posture
- G.R. No. L-19069, decided October 29, 1968 by the Supreme Court of the Philippines, on automatic review of Criminal Case No. 7705 of the Court of First Instance of Rizal.
- Six of twenty-two originally charged inmates—Amadeo Peralta, Andres Factora, Leonardo Dosal, Angel Parumog, Gervasio Larita and Florencio Luna—found guilty of multiple murder and sentenced to death.
- Lower court also ordered joint and several indemnity of ₱6,000 to heirs of each victim, plus costs.
Parties and Charge
- Plaintiff-Appellee: The People of the Philippines.
- Defendants-Review: Amadeo Peralta, Andres Factora, Leonardo Dosal, Angel Parumog, Gervasio Larita and Florencio Luna.
- Information charged conspiracy to commit multiple murder on or about February 16, 1958 at New Bilibid Prison, Muntinlupa, Rizal, under aggravating circumstances and quasi-recidivism.
Aggravating Circumstances Alleged
- Insult to public authorities.
- Commission by a band.
- Commission by armed persons affording impunity.
- Use of superior strength or means.
- Breaking doors and windows to facilitate crime.
- Means adding ignominy.
- Commission where public authorities were performing duties.
- Quasi-recidivism: accused were serving final sentences when offense occurred.
Factual Background
- Since 1956, two rival gangs in penitentiary: “Sigue-Sigue” (predominantly Tagalogs) vs. “OXO” (mainly Visayan/Mindanao inmates).
- Segregation: Building 1 housed Sigue-Sigue; Building 4, especially Brigade 4-A, housed OXO.
- February 16, 1958, riot erupted during Sunday mass assembly after an initial scuffle in the plaza.
- Sigue-Sigue in Building 1 attempted to invade Building 4 but were repelled by guards.
- OXO inmates in 4-A thereafter destroyed locks of brigades 4-B, 4-C and 4-D, invaded them, and targeted known Tagalog inmates.
Victims and Injuries
- Jose Carriego (4-B): multiple fatal chest punctures, lacerations to lip, contusion of neck. Cause of death: internal hemorrhage.
- Eugenio Barbosa (4-C): head laceration, penetrating abdominal wounds, wounds on axilla and extremities. Cause of death: shock and internal hemorrhage.
- Santos Cruz (4-C/4-A): skull fracture, lip wo