GR 38095; (August, 1981) (Digest)
G.R. No. L-38095 August 10, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee vs. CARLOS MELENDRES, ANTONIO GERODIAS and SOFRONIO GONZALES, defendants-appellants.
FACTS
This is an automatic review of a death penalty conviction for murder and frustrated murder. The incident occurred inside the New Bilibid Prison on September 28, 1971, where inmates Angel Montero and Aniano Catipay were stabbed by fellow prisoners belonging to the OXO-KKK gang. Montero died from nine stab wounds, while Catipay survived eleven stab wounds, including a near-fatal abdominal injury. Initial investigation by prison guard Primitive Arias, based on eyewitness Nimrod Egonia’s account, identified appellants Carlos Melendres, Antonio Gerodias, Sofronio Gonzales, and Rodolfo Molina (who died during trial) as the assailants. The appellants later executed sworn affidavits regarding the incident.
ISSUE
Whether the guilt of the appellants for the crimes of murder and frustrated murder was proven beyond reasonable doubt, and whether the imposition of the death penalty was proper.
RULING
The Supreme Court affirmed the appellants’ conviction but modified the penalty. The Court found the trial court’s factual findings, supported by clear and convincing evidence, to be conclusive. Melendres admitted to stabbing Catipay but denied involvement in Montero’s killing, claiming his affidavit confession was coerced. However, the Court noted he affirmed executing the affidavit voluntarily before Arias without intimidation. Gerodias and Gonzales also affirmed their affidavits but offered implausible alibis. The positive identification by victim Catipay and the circumstantial evidence solidified their culpability in a concerted assault. The Court agreed with the qualification of treachery, as the sudden attack on the unsuspecting victims, who were conversing with the appellants, ensured the assault’s execution without risk to the assailants. While the appellants are quasi-recidivists warranting the death penalty under strict law, the Court commuted it to reclusion perpetua. Citing judicial notice of the wretched, congested, and dehumanizing conditions within the New Bilibid Prison, which exacerbate inmate behavior rather than rehabilitate, the Court held that justice tempered with compassion justified the reduction of the penalty, following precedent in People vs. Garcia. The judgment was modified accordingly.