Case Summary (G.R. No. 137266)
Charges and Court Proceedings
The Circuit Criminal Court of Pasig, Rizal, found the accused guilty of murder under Article 248 of the Revised Penal Code, resulting in a death penalty. The prosecution alleged that the accused conspired to attack the unarmed Santiago, inflicting multiple stab wounds that ultimately led to his death. The information was filed on April 17, 1973, and the court's decision was rendered on April 26, 1974.
Witness Testimonies
The prosecution relied heavily on the testimony of Rogelio Bulalayao, a fellow inmate, who recounted witnessing the attack. Bulalayao testified that he observed the accused in a suspicious gathering before the assault and warned Santiago, who, however, disregarded the warning. He later testified to seeing Resurreccion stab Santiago and witnessed the other accused participate in the assault. An autopsy confirmed that Santiago died from multiple stab wounds, three of which were mortal.
Defense Strategies
The defense presented alibis claiming the accused were together in another dormitory at the time of the murder. Additionally, they disputed the credibility of Bulalayao's testimony, arguing that he was motivated by self-preservation to implicate them. The accused contended that they did not know Santiago and were not involved in the stabbing.
Evaluation of Credibility
The court evaluated the credibility of witness testimonies and found Bulalayao's account compelling, especially given the corroborative testimony from the defense witness, Gilberto Llamoso. Despite the typical assumptions regarding the unreliability of convict testimony, the court found no evidence of coercion or motive for Bulalayao to falsely incriminate the accused.
Examination of the Accused's Alibis
The defense's alibi was weakened by inconsistencies, particularly in Atienza's testimony regarding the timing of their transfer to Dormitory 4-C. The court noted that the door to their dormitory being padlocked did not preclude the possibility of them committing the crime before their claimed confinement.
Analysis of Aggravating and Mitigating Circumstances
The court did not find mitigating circumstances to favor the appellants but established the presence of aggravating factors including abuse of superior strength due to the attackers being armed while the victim was not. Maranan's prior conviction for frustrated murder constituted an additional aggravating circumstance of recidivis
...continue readingCase Syllabus (G.R. No. 137266)
Case Overview
- The case involves an automatic review of the decision dated April 26, 1974, from the Circuit Criminal Court of Pasig, Rizal.
- The accused—Danilo Resurreccion, Romeo Maranan, and Amador Atienza—were sentenced to death for the crime of murder.
- The court found them guilty beyond reasonable doubt, ordering them to indemnify the heirs of the victim, Suliman Santiago, and to pay moral and exemplary damages.
Incident Summary
- The crime occurred on March 25, 1971, around 3:00 p.m. at the New Bilibid Prison in Muntinlupa, Rizal.
- Suliman Santiago, an inmate, was stabbed to death in front of the prison boxing office after being pursued and attacked by the accused.
- Santiago was unarmed and suffered multiple stab wounds, three of which were fatal.
Prosecution Witnesses
- Rogelio Bulalayao, a key prosecution witness, testified that he saw the three accused conspiring before the attack.
- He observed the assault and described how the accused attacked Santiago with improvised deadly weapons.
- The necropsy report confirmed Santiago died from multiple stab wounds inflicted by sharp instruments.
Defense Presentation
- The defense presented Gil