G.R. No. L-40294 July 11, 1986
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TOBIAS RIBADAJO, ROMEO CORPUZ, FEDERICO BASAS, ROSENDO ANOR and RODOLFO TORRES, defendants-appellants.

FACTS

The case involves the murder of fellow inmate Bernardo Cutamora within the New Bilibid Prison. The appellants, all prisoners, were charged after a coordinated attack on November 18, 1971. Prisoners from brigade 3-C used a false key to exit their dormitory and attacked inmates from brigade 3-A while the latter were receiving food rations. The victim, Cutamora, was simultaneously stabbed by multiple assailants, sustaining fatal wounds. The motive was revenge for prior mockery and the throwing of human waste by inmates of brigade 3-A, who were members of a rival group called OXO, against the appellants’ Sigue-Sigue Commando Gang. Following an investigation, all accused executed extrajudicial confessions admitting their roles in the planned killing.
Upon arraignment, several appellants initially pleaded guilty but later, during the presentation of defense evidence, withdrew these pleas and repudiated their confessions, claiming they were extracted under duress through beatings and exposure to the elements. The trial court, however, convicted all five surviving appellants of murder and imposed the death penalty. The case is under automatic review.

ISSUE

The primary issue is whether the extrajudicial confessions of the appellants are admissible and sufficient to sustain their conviction for murder.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the admissibility and credibility of the extrajudicial confessions. The legal logic centered on the inherent reliability and voluntariness of the statements, as evidenced by their detailed contents. The confessions contained specific facts known only to the perpetrators, such as the planning meeting at 1:00 PM, the use of a false key, the timing of the attack during “rancho” distribution, the nicknames of co-accused, and the motive rooted in gang rivalry. These intricate details could not have been concocted by investigators. The appellants’ claim of coercion was deemed unsupported by the records, and their subsequent attempt to plead guilty to a lesser offense of homicide further undermined their denial of involvement.
Regarding the crime’s classification, the Court found the killing was attended by treachery. The attack was sudden and executed in a manner that ensured the victim, who was unarmed and preoccupied with getting food, had no opportunity to defend himself. This qualified the crime as murder. However, the Court rejected the aggravating circumstance of evident premeditation due to insufficient proof of a sufficient lapse of time between the plan and its execution to allow for reflection. Recidivism was also not established as the prior convictions were not duly proven. Consequently, with no aggravating or mitigating circumstances, the penalty for murder was reclusion temporal in its maximum period to death. Applying the Indeterminate Sentence Law, the Court modified the penalty to an indeterminate sentence ranging from ten years and one day of prision mayor as a minimum, to reclusion perpetua as a maximum. The awards for civil indemnity and damages were sustained.