G.R. No. 139230 - People vs. Daniela

Ronito Enero, his common-law wife Maria Fe Balo, and their three young children lived in a modest dwelling in Cebu City and earned a living vending fish at the public market.
The household also included a helper (Leo Quilongquilong, the cousin of Maria Fe) and a house-help (Julifer Barrera).
Manuel Daniela (alias Manuel de la Cruz @ Tagalog) had a past association with Ronito in Davao City, while his wife, Imelda, was a friend and former classmate of Maria Fe.

On March 28, 1996, Manuel and his accomplice Jose Baylosis arrived in Cebu City and lodged at the residence of Joel Colejara in Pardo.
The duo made contact with Maria Fe at the market, where she disclosed the location of her residence.
Soon after, Manuel visited Ronito and Maria Fe’s house on several occasions, even borrowing P800 from them.
On the evening of March 30, 1996, after a drinking spree with Ronito and Manuel, Maria Fe and the house help retired for the night while Leo slept in the living area.

At approximately 2:00 a.m., Manuel, armed with a .38 caliber pistol and a kerosene lamp (and later a grenade), forcibly entered the bedroom.

He ordered Maria Fe to lie down by threatening her with the gun.
Jose, armed with a knife, followed and assisted in restraining Maria Fe by tying her hands and taping her mouth.

Following orders from Manuel, Leo was also awakened and tied.
The offenders proceeded to divest Maria Fe of her jewelry (a necklace, rings, and earrings) and demanded money.

Despite her claim that her money had been used for business purposes, they ransacked the room.
Under threat of a grenade explosion, Maria Fe eventually surrendered P30,000 (kept in her waist pouch) along with a Seiko wristwatch.

Ronito was repeatedly stabbed with a kitchen knife after being covered with a blanket.
Both offenders contributed to the fatal assault, with additional stabbings and blunt force impacts.

Post-crime, Manuel rapes Julifer after untieing her, and both perpetrators remained at the scene until 4:00 a.m.
Before leaving, they asserted that orders came from other conspirators and threatened the victims to maintain silence.

Despite threats, Leo and Maria Fe managed to untie themselves and reported the incident to Barangay Chairman Sergio OcaAa.
Dr. Jesus P. Cerna conducted a detailed autopsy on Ronito, recording multiple stab wounds, lacerations, and the cause of death as acute hemorrhage from massive blood loss.
An Information was filed on July 17, 1996, charging Manuel and Jose with robbery with homicide, including specific details of stolen valuables and the amount involved.

Upon arraignment on October 17, 1996, both accused initially pleaded not guilty.
During trial proceedings, on February 4, 1997, Manuel and Jose offered to withdraw their plea of not guilty and enter a plea of guilty to the charged crime.
Although the prosecution continued with its evidence (including testimonies from Maria Fe and Barangay Captain OcaAa), the accused later later admitted to involvement, with Manuel acknowledging the killing of Ronito.
The trial court, in its decision dated March 31, 1997, relied on the plea of guilty—later deemed improvident—and the evidence presented to convict them of robbery with homicide, imposing the death penalty and ordering restitution for the stolen items.

Whether Manuel’s and Jose’s change of plea from not guilty to guilty was made with full comprehension of its consequences, particularly given that the crime is a capital offense.
Whether the trial court conducted a sufficiently “searching inquiry” into their understanding of the plea’s legal implications as required under Section 3, Rule 116 of the Revised Rules of Criminal Procedure.

Whether independent evidence, apart from their plea of guilty, established beyond reasonable doubt all the elements of robbery with homicide.
Whether the testimony of Maria Fe, despite possible credibility issues, was probative enough to support the conviction.

Whether the aggravating circumstances—specifically the nighttime and dwelling factors—were properly alleged and proven, thereby justifying the imposition of the death penalty (or reclusion perpetua, as modified on appeal).
Whether such circumstantial evidence was adequately connected to the robbery and homicide elements under Article 294 of the Revised Penal Code.

Whether retroactive application of Rule 110, Sections 8 and 9 of the Revised Rules of Criminal Procedure is warranted under the interest of justice in this capital case.

Whether the trial court’s orders regarding restitution (return of stolen jewelry) and the imposition of moral and exemplary damages conform with current jurisprudence and the provisions of the Revised Penal Code and the Civil Code.