Case Summary (G.R. No. L-48642)
Incident Overview
On the morning of September 24, 1975, six prison kitchen workers from the G.I.G. gang arrived at Dormitory No. 4-D to deliver breakfast. As they unloaded food from their truck, members of the Sigue-Sigue Sputnik gang, under the leadership of Generoso Dungca, attacked them with improvised weapons after Dungca commanded, "Kill them all." The attack led to severe injuries and ultimately the death of Cirilo Monroy from multiple stab wounds.
Charges and Indictment
Following the violent incident, the defendants were charged with murder and multiple frustrated murder in an information filed by the Provincial Fiscal of Rizal on February 3, 1977. The defendants were arraigned on February 10, 1977, where Tomas Salcedo pleaded guilty while the other defendants pleaded not guilty. The gang leader, Generoso Dungca, was not arraigned due to his escape from prison.
Trial Court Decision
On August 30, 1977, the trial court found the accused guilty beyond a reasonable doubt. Each defendant was sentenced to death for the murder of Cirilo Monroy, as well as to 17 years and four months to 20 years of reclusion temporal for the multiple frustrated murders of the injured kitchen workers. The defendants were also ordered to indemnify the heirs of Monroy and pay moral and exemplary damages.
Issues Raised on Appeal
The primary contention raised in the appeal against the trial court's ruling concerned the sufficiency of the evidence. The defendants argued that the prosecution failed to establish their guilt beyond a reasonable doubt. The trial court concluded that the defendants, having premeditated the attack while armed, acted with evident treachery, negating the arguments of self-defense they presented.
Self-Defense Argument
The defendants contended that the attack was provoked when Cirilo Monroy approached with a bottle of wine, leading to an altercation where Salcedo parried Monroy's attack. They claimed that subsequent actions were defensive in nature. The trial court found no credible evidence to support this claim, noting that the victims were unarmed at the time of the incident and that none of the defendants were injured during the altercation.
Evidence and Findings
The court supported its conclusion with testimonies identifying the defendants as the aggressors, and established that the weapons used in the attack had been prepared in advance. The court deemed the defendants' self-defense claims implausible given the circumstances and the imbalance of injuries between the parties involved.
Review and Outcome
The case was reviewed by the Supreme Court, affirming the tri
...continue readingCase Syllabus (G.R. No. L-48642)
Case Overview
- This case involves the review of a decision made by Judge Onofre A. Villaluz of the then Circuit Criminal Court of Pasig, Metro Manila, dated August 30, 1977.
- The accused, Tomas Salcedo, Roberto Esguerra, Roberto Madayao, and Alberto Leban, were convicted of Murder and Multiple Frustrated Murder.
- The events occurred within the confines of the National Penitentiary, or New Bilibid Prison, in Muntinlupa, Metro Manila.
Background of the Incident
- The incident transpired on September 24, 1975, around 10:00 AM.
- Victims, six kitchen boys from the G.I.G. (Genuine Ilocano Gang), were attacked by members of the Sigue-Sigue Sputnik gang while delivering breakfast.
- The attackers utilized improvised deadly weapons and acted on the command of their leader, Generoso Dungca, who ordered, "Kill them all".
- The melee was quelled by prison guards, and the injured were taken to the NBP Hospital for treatment.
Victim and Injury Details
- Cirilo Monroy, one of the victims, sustained fatal injuries and died due to multiple stab wounds.
- Other victims, including Rodolfo Querrer, Virgilio Domingo, Jose Obanil, Aniceto Nino, and Pacifico Catabay, suffered serious stab wounds but survived due to timely medical intervention.
- The injuries were confirmed by medical professionals, establishing the severity of the attacks.