Case Summary (G.R. No. L-38755)
Incident Overview and Charges
On that day, the accused devised a plan to attack members of the opposing gang in retaliation for prior murders. Armed with improvised weapons, they executed their plan, resulting in the fatalities of Tilosa and Abril, and the serious injury of Francisco. Following the assault, the accused voluntarily surrendered to prison authorities and executed confessions regarding the incident.
Proceedings and Testimonies
The trial centered on the validity of the extrajudicial confessions made by the accused. The investigator, Francisco A. Cometa, testified to the manner in which the confessions were obtained and asserted their voluntariness. Despite this, the accused later repudiated their confessions, claiming coercion and lack of understanding of the documents they signed. They presented varying testimonies about their involvement in the crime and the conditions under which they made their confessions.
Trial Court's Decision
The trial court found the accused guilty of murder and frustrated murder, qualifying the crimes by treachery and evident premeditation. The court imposed the death penalty for murder, taking into account the aggravated circumstances surrounding the offenses due to the gang rivalry and previous incidents of violence within the prison.
Appeal and Review Process
The case was automatically reviewed by the Supreme Court due to the imposition of the death penalty. The accused did not appeal the trial court's decision; however, the review questioned the sufficiency of evidence and the application of the death penalty given the unique circumstances of the cases emanating from the brutality present in the national penitentiary.
Supreme Court's Ruling
In their ruling, the Supreme Court acknowledged the validity of the extrajudicial confessions as conclusive proof of guilt despite the accused's claims of coercion. The Court determined that the multiple acts of violence committed during the conspiracy constituted a complex crime under Article 48 of the Revised Penal Code and affirmed the original conviction but altered the sentences to reclusion perpetua instead of the death penalty. This reduction was supported by precedents involving multiple murders occurring in a similar context and highlighted concerns related to the inhumane conditions within the penitentiary system.
Dissenting Opinion
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Case Background
- The case pertains to a convict-against-convict murder incident occurring within the confines of the national penitentiary.
- The incident occurred on Good Friday, April 9, 1971, and involved a violent clash between two rival gangs: the Oxo gang and the Sigue-Sigue Sputnik (SSS) gang.
- The accused, Jose Pincalin, Rodolfo Beltran, Eduardo Empleo, and Alejandro Jandomon, all members of the Oxo and Happy-Go-Lucky gangs, conspired to avenge the deaths of fellow gang members.
Facts of the Case
- At approximately 10:00 AM on the day of the incident, the accused enlisted their roles in the planned killings:
- Pincalin was to kill Leonardo Francisco.
- Beltran and Empleo were to kill Victorino Abril.
- Jandomon was tasked with killing Florentino Tilosa.
- The accused armed themselves with improvised bladed weapons known as "matalas."
- The actual assaults began about an hour later:
- Beltran and Empleo approached Abril, who was seated on his bed, and stabbed him multiple times.
- Jandomon attacked Tilosa near the dormitory door, stabbing him repeatedly.
- Pincalin stabbed Francisco as he attempted to escape through a window after witnessing the assault on Abril.
- Following the attacks, the accused surrendered to prison authorities and executed separate extrajudicial confessions in Tagalog.
Evidence and Confessions
- The autopsy reports indicated:
- Tilosa suffered six stab wounds, two of which were fatal.
- Abril had sustained fourteen stab wounds, one fatal.
- Francisco sustained a serious stab wound that required surgical intervention.
- The primary