People v. Dioso
REITERATIONFacts
The Antecedents: Teofilo Dioso and Jacinto Abarca, both inmates serving sentences at the New Bilibid Prison, were members of the "Batang Mindanao" gang. The victims, Angelito Reyno and Fernando Gomez, were members of the rival "Happy Go Lucky" gang. Following the death of a "Batang Mindanao" member, allegedly at the hands of "Happy Go Lucky" members, Dioso and Abarca, suspecting Reyno and Gomez of involvement, planned to avenge their fallen comrade. They found an opportunity when they learned the victims were sick and confined in the prison hospital. On September 12, 1972, at approximately 6:15 AM, Abarca feigned illness to gain admission to the hospital, accompanied by Dioso. Inside Ward 6, they found Reyno eating breakfast and Gomez lying on a wooden bed under a mosquito net. Dioso approached Reyno, while Abarca went towards Gomez. Both accused then drew improvised knives. Abarca lifted the mosquito net and stabbed Gomez, while Dioso simultaneously attacked Reyno. After Reyno fell, Dioso assisted Abarca in stabbing Gomez. Upon exiting Ward 6, they surrendered to Prison Guard Enriquito Aguilar, handing over their weapons. Autopsies performed by Dr. Ricardo E. Baryola revealed that both victims died of massive bleeding due to multiple stab wounds. The accused readily admitted responsibility in sworn statements, detailing the commission of the crime and identifying the motive as revenge for the death of their gangmate, Balerio. Procedural History: The accused were arraigned for murder and voluntarily entered a plea of guilty. The trial court proceeded to present evidence to determine culpability. The accused acknowledged the voluntary execution of their confessions. The Circuit Court of Rizal imposed the death sentence upon both Teofilo Dioso and Jacinto Abarca. The Petition: The case was elevated to the Supreme Court for mandatory review of the death sentences. The appellants sought attenuation of the death sentence by invoking the circumstances of voluntary surrender and plea of guilty.
Issue(s)
Whether the accused are guilty of murder. Whether the mitigating circumstances of voluntary surrender and plea of guilty should attenuate the penalty imposed, considering the commission of the crime while serving sentence for prior offenses.
Ruling
The Supreme Court affirmed the conviction for murder but, for lack of the requisite votes, commuted the death sentence imposed on each accused to reclusion perpetua. The accused were ordered to jointly and severally indemnify the heirs of the deceased in the amount of P30,000.00.
Ratio Decidendi
On the guilt of the accused for murder: The Court found that the crime was perpetrated with alevosia. As admitted by the accused, they inflicted the fatal blows while Gomez was lying down under a mosquito net and Reyno was taking his breakfast. This clearly indicates that neither victim was in a position to defend himself from the sudden and unexpected assault. The confessions of the accused, corroborated by the autopsy findings, established their culpability for murder. On the penalty to be imposed: The Court noted that the accused were quasi-recidivists, having committed the crime charged while serving sentences for prior offenses. Article 160 of the Revised Penal Code mandates that in cases of quasi-recidivism, the maximum penalty prescribed by law for the new felony shall be imposed, regardless of the presence or absence of mitigating or aggravating circumstances. Therefore, the death penalty was correctly imposed by the trial court. However, due to the lack of the requisite votes for the imposition of the death penalty, the Court was constrained to commute the sentence to reclusion perpetua.
Main Doctrine
Quasi-recidivism, as defined under Article 160 of the Revised Penal Code, mandates the imposition of the maximum penalty prescribed by law for the new felony, irrespective of the presence or absence of mitigating or aggravating circumstances.