G.R. No. L-19069 October 29, 1968
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AMADEO PERALTA, ET AL., defendants, ANDRES FACTORA, LEONARDO DOSAL, ANGEL PARUMOG, AMADEO PERALTA, FLORENCIO LUNA and GERVASIO LARITA, defendants-review.

FACTS

The case involves a multiple murder that occurred on February 16, 1958, at the New Bilibid Prisons in Muntinglupa, Rizal. The accused, all convicts serving final sentences, were charged with the killings of fellow inmates Jose Carriego, Eugenio Barbosa, and Santos Cruz. The killings were an offshoot of the rivalry between two prison gangs, the “Sigue-Sigue” (predominantly Tagalog) and the “OXO” (mainly from Visayas and Mindanao). After a fight between rival gang members in the plaza was quelled, inmates from Brigade 4-A (mostly OXO members) rampaged through Building 4. They forcibly opened the doors of Brigades 4-B and 4-C, specifically hunting for Tagalog inmates. Jose Carriego was clubbed and stabbed to death in 4-B by Andres Factora, Amadeo Peralta, and Leonardo Dosal. Eugenio Barbosa and Santos Cruz were similarly clubbed and stabbed to death in 4-C by a group including Factora, Dosal, Angel Parumog, Gervasio Larita, Florencio Luna, and others. The prosecution presented multiple inmate witnesses who identified the accused as the assailants. The trial court convicted the six accused-review and sentenced them to death.

ISSUE

The primary issue for review is the correctness of the conviction and the imposition of the death penalty for multiple murder, considering the evidence presented and the applicable aggravating circumstances.

RULING

The Supreme Court affirmed the conviction. The defense of alibi and denial by the accused was rejected, as they were positively identified by prosecution witnesses. The claim of self-defense by accused Amadeo Peralta was found untenable. The killings constituted the complex crime of multiple murder under Article 48 of the Revised Penal Code, as a single act (the concerted riot and attack) resulted in the deaths of three persons. The aggravating circumstances of quasi-recidivism (the accused were convicts serving final sentences), evident premeditation, treachery, and band were properly appreciated. The circumstance of insult or disregard of public authority was also present, as the crimes were committed inside a penal institution, directly challenging the State’s custodial authority. With no mitigating circumstances to offset the aggravating ones, the imposition of the death penalty was proper. The court also affirmed the award of indemnity to the heirs of each victim.