People v. Dueñas
REITERATIONFacts
1. The Antecedents: Fighting occurred among prisoners in the National Penitentiary between the "Sigue-sigue" gang (Manila boys) and the "OXO" gang (Visayans and Ilocanos), with "Sigue-sigue" occupying Brigade 3-A and "OXO" occupying Brigade 3-D. On the early morning of February 17, 1958, inmates from Brigade 3-D, including Juanito Tobias, Constantino Dueñas, and Custodio Mainar, approached Dionisio Valdez to help break down the door of Brigade 3-A. Simultaneously, Nataniel Labampa, accompanied by Angel Flores, Custodio Mainar, and Pablo Roxas, also from Brigade 3-D, went to Brigade 3-A to have its door opened. While there, they witnessed appellant Constantino Dueñas emerging from Brigade 3-B with Carlos de los Reyes, the food distributor. As they moved towards the fire escape, Felipe Gonzales struck De los Reyes on the head with a piece of wood, causing him to fall, after which Juanito Tobias stabbed him in the chest. Sofronio Dagami and Pablo Roxas then lowered the body down the fire escape. Evidence indicated that on the night of February 16, members of the "OXO" gang in Brigade 3-D agreed to take revenge against the "Sigue-sigue" gang, breaking their lock and preparing sharp instruments, with Custodio Mainar inciting revenge and Juanito Tobias and Felipe Gonzales assisting in destroying the lock, their stated purpose being to avenge companions killed the previous day. Carlos de los Reyes was a member of the "Sigue-sigue" gang, and the autopsy revealed his death was caused by strangulation, a stab wound to the chest, and lacerated wounds on the forehead, with neck equimosis indicating strangulation by a cloth. All accused denied participation, attributing the act to Jose de la Cruz, who was acquitted, and De la Cruz's affidavit claiming responsibility was denied by him at trial. Felipe Gonzales denied striking De los Reyes, claiming he was inside his brigade, as did Juanito Tobias, who also denied being an "OXO" member. Custodio Mainar claimed he was sleeping and unwell, while Constantino Dueñas denied being with De los Reyes and stated Jaime, not De los Reyes, provided food. Loreto Villanueva testified for Dueñas, stating Dueñas was cleaning the dormitory, but this testimony was deemed insufficient. 2. Procedural History: The accused-appellants were found guilty of murder by the Court of First Instance of Rizal and were sentenced to death, ordered to indemnify the heirs of Carlos de los Reyes, and to pay costs. 3. The Petition: Appellants Constantino Dueñas, Felipe Gonzales, Juanito Tobias, Angel Flores, Sofronio Dagami, Pablo Roxas, and Custodio Mainar appealed their conviction and sentence to death.
Issue(s)
Whether the conspiracy to commit murder was sufficiently established among the accused-appellants. Whether treachery attended the commission of the crime, qualifying it as murder. Whether all the accused-appellants are liable for the death of Carlos de los Reyes, or only those who directly participated in the assault. Whether the penalty of death imposed by the trial court is proper.
Ruling
The Court affirmed the conviction and sentence of death for Constantino Dueñas, Felipe Gonzales, and Juanito Tobias. The judgment and sentence imposed upon Angel Flores, Sofronio Dagami, Pablo Roxas, and Custodio Mainar were set aside, and they were acquitted. The costs were assessed proportionately against the three convicted appellants.
Ratio Decidendi
On Issue 1: The Court found that a conspiracy to commit murder was established among the accused-appellants. This was evidenced by their agreement on the night of February 16 to take revenge against the "Sigue-sigue" gang, their preparation of sharp instruments, and the breaking of their brigade's lock. The act of asking Valdez and Labampa, who were "Manila boys" and companions, to go with them to Brigade 3-A was seen as a ruse to facilitate entry. The collective intent to avenge their fallen companions demonstrated a common purpose to commit an unlawful act. On Issue 2: Treachery was found to have qualified the killing as murder. The victim, Carlos de los Reyes, was attacked suddenly by Felipe Gonzales, who struck him on the head with a piece of wood, causing him to fall. Subsequently, Juanito Tobias stabbed the fallen victim. Constantino Dueñas was seen leading De los Reyes out of Brigade 3-B towards the fire escape. The attack was executed without provocation and without opportunity for the victim to defend himself, fitting the definition of treachery under the Revised Penal Code. On Issue 3: The Court held that only Constantino Dueñas, Felipe Gonzales, and Juanito Tobias were directly responsible for the death of Carlos de los Reyes. While there was a conspiracy to take revenge, the Court found no agreement to kill every "Manila boy" encountered. The participation of Dueñas in leading the victim out, Gonzales in striking the fatal blow, and Tobias in stabbing the victim was clear and positive. As to Dagami and Roxas, they only helped lower the body down the fire escape and did not participate in the attack itself. The Court reasoned that the conspiracy was aimed at attacking the inmates of Brigade 3-A, not specifically De los Reyes or any "Manila boy" who might come their way. Therefore, the other appellants could not be held responsible for the death directly effected by the three. On Issue 4: The penalty of death imposed by the trial court was affirmed for the three convicted appellants. The crime committed was murder, qualified by treachery. Since the appellants were serving sentences at the time of the commission of the crime, Article 160 of the Revised Penal Code mandates the imposition of the maximum penalty prescribed by law for murder, which is death. No mitigating circumstances were found to have attended the commission of the offense.
Main Doctrine
The Court reiterated that conspiracy to commit murder can be established through the collective actions of individuals, even if their individual participation in the fatal act is not direct. Furthermore, the presence of treachery as a qualifying circumstance for murder was affirmed, emphasizing that an attack executed suddenly and without any chance for the victim to defend himself, regardless of the method used to lure him into the attack, constitutes treachery. The ruling also clarified that inmates serving sentences who commit further crimes are subject to the maximum penalty prescribed by law, which in this case was death for murder.