G.R. No. L-44188. January 27, 1981.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BENIGNO PEREZ and ERNESTO ARAMBULO, defendants-appellants.

FACTS

On the evening of April 13, 1971, inmate Ernesto Witack was fatally stabbed by several assailants inside the New Bilibid Prisons in Muntinglupa, Rizal. Prison guards Juanito Bagabag and Amado Dandoy witnessed the attack and rushed to intervene. Guard Bagabag positively identified fellow prisoners Benigno Perez and Ernesto Arambulo among the assailants, clubbing them to stop the assault. Eyewitness prisoners Ernesto Samson and Benjamin Moya corroborated the guards’ account, detailing how Arambulo initiated the attack by embracing Witack before stabbing him, with Perez immediately joining in. The autopsy revealed eight stab wounds, with one fatal injury severing a renal artery.
Both accused subsequently executed sworn extrajudicial confessions before prison investigators. Perez admitted to stabbing Witack five times, confirming a prior agreement with Arambulo made that same afternoon. Arambulo confessed to being the first to stab Witack, citing the victim’s role as a weapon supplier for a rival prison gang. Upon arraignment, both accused pleaded guilty to the charge of Murder. The trial court, considering the presence of treachery and the special aggravating circumstance of quasi-recidivism (as Arambulo was a convicted prisoner at the time), sentenced both to death.

ISSUE

Whether the trial court correctly imposed the death penalty upon the accused, considering their plea of guilty and the attendant circumstances.

RULING

Yes, the Supreme Court affirmed the imposition of the death penalty. The legal logic proceeds from the proper appreciation of the circumstances. The crime was clearly Murder, qualified by treachery (alevosia), as the attack was sudden and rendered the victim unable to defend himself. The special aggravating circumstance of quasi-recidivism under Article 160 of the Revised Penal Code was also present, as the offense was committed by persons who were already serving sentence at the time. While the ordinary mitigating circumstance of a plea of guilty was present, the Court ruled that such an ordinary mitigating circumstance cannot offset a special aggravating circumstance. Following the rules for penalty imposition in Article 63, when the penalty prescribed by law is a single indivisible one (like death) and a special aggravating circumstance is present without any other mitigating circumstance to offset it, the penalty must be imposed in its maximum period. Consequently, the death penalty was the correct penalty. The Court found the confessions voluntary and the evidence of guilt, including eyewitness testimonies, conclusive.