G.R. No. L-38180 October 23, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SALVADOR CRISOSTOMO and INOCENCIO RAGSAC, accused-appellants.

FACTS

Accused-appellants Salvador Crisostomo and Inocencio Ragsac, inmates at the New Bilibid Prison, were charged with murder for the killing of fellow prisoner Antonio Waje on May 27, 1972. The information alleged they conspired, armed with improvised bladed weapons, and attacked Waje with treachery, evident premeditation, and deliberate intent to kill. Both accused pleaded not guilty. The trial court found them guilty and imposed the death penalty, prompting an automatic review. The prosecution established that days before the incident, Crisostomo gave Waje money to buy items, which Waje claimed was lost. This, coupled with Crisostomo’s grudge over Waje’s past killing of prison guards who were Crisostomo’s friends, led the appellants to plan the killing. On the morning of May 27, they waited for Waje, followed him, and took turns stabbing him seven times, resulting in his death.
After the stabbing, both appellants were treated for minor injuries. They subsequently executed sworn statements admitting to the killing, with Crisostomo citing his grudge and the lost money as motives, and Ragsac stating he participated because Crisostomo asked him to. During trial, they recanted these statements, claiming they were extracted through force and that they acted in self-defense against an armed Waje. The trial court rejected this defense, finding the confessions voluntary and the claim of self-defense unsupported by evidence.

ISSUE

The core issue is whether the trial court erred in convicting the appellants of murder and imposing the death penalty, specifically concerning the validity of their extrajudicial confessions, the presence of treachery, and the proper penalty.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the trial court’s finding that the extrajudicial confessions were voluntarily executed. The appellants were informed of their rights, the statements were given in Tagalog, a language they understood, and they were assisted by a prison official. Their bare allegations of coercion, unsupported by evidence, were insufficient to invalidate the confessions, which were corroborated by the physical evidence and the circumstances of the crime.
The Court found the killing was attended by treachery. The appellants deliberately waited for the victim, followed him, and launched a sudden and unexpected attack with lethal weapons while he was unarmed and unable to defend himself. This method ensured the execution of the crime without risk to themselves. The claim of self-defense was correctly rejected, as the nature and number of the victim’s wounds were inconsistent with a sudden, violent altercation initiated by the victim. The appellants’ flight and recantation further indicated guilt.
The crime is murder qualified by treachery. The aggravating circumstance of recidivism was present for both appellants due to their previous final convictions. However, for lack of the necessary votes to impose the death penalty, the Court imposed the penalty of reclusion perpetua. The indemnity to the victim’s heirs was increased to P12,000.00. The decision of the trial court was affirmed with these modifications.