Case Digest (G.R. No. 139230)
Facts:
The People of the Philippines v. Manuel Daniela alias Manuel de la Cruz @ Tagalog and Jose Baylosis y Baisac, G.R. No. 139230, April 24, 2003, the Supreme Court En Banc, Callejo, Sr., J., writing for the Court.The appellants are Manuel Daniela (alias Manuel de la Cruz @ Tagalog) and Jose Baylosis; the appellee is the People of the Philippines. They were charged in the Regional Trial Court (Branch 18, Cebu City) in Criminal Case No. CBU-42044 with robbery with homicide for the March 31, 1996 killing of Ronito Enero and the robbery of items from Ronito and his common-law wife Maria Fe Balo. The RTC rendered a decision dated March 31, 1997 convicting both appellants of robbery with homicide, imposing the death penalty, ordering joint and several civil indemnity of P50,000 to the heirs of the victim, and restitution of the stolen cash and jewelry.
The factual background: Ronito and Maria Fe lived in Pasil, Cebu City with three young children, a cousin Leo Quilongquilong, and househelp Julifer Barrera. Manuel and Jose arrived in Cebu City on March 28, 1996; Manuel knew Maria Fe and had previously borrowed P800 from the couple. On the night of March 30–31, 1996, Manuel and Jose went to the couple’s house, drank with Ronito, and later returned at about 2:00 a.m. Manuel entered the bedroom armed with a .38 and a kerosene lamp; Jose entered with a knife. According to Maria Fe’s testimony, both tied the occupants, threatened them with a grenade, rifled the room, took jewelry and money, and then jointly stabbed Ronito repeatedly; Julifer was raped. Leo and Maria Fe escaped and reported the incident to the barangay. An autopsy by Dr. Jesus Cerna established multiple stab wounds and hemorrhage as cause of death.
An information was filed on July 17, 1996. At arraignment the accused pleaded not guilty. During trial, on February 4, 1997, both appellants sought to withdraw their not-guilty pleas and pleaded guilty to the charge; the prosecution agreed and the accused were rearraigned. The prosecution nevertheless proceeded to present witnesses (including Maria Fe and Barangay Captain Ocana); the defense presented Manuel’s testimony claiming self-defense and an initial purpose to demand a share of prior loot. The RTC convicte...(Pro-only)
Issues:
- Was the appellants’ plea of guilty to the capital offense improvident, and if so, can their conviction rest solely on that plea?
- Did the prosecution prove beyond reasonable doubt the elements of robbery with homicide under Article 294, as amended?
- Were the aggravating circumstances of dwelling and nighttime sufficiently alleged and proven to justify the supreme penalty?
- Should the rule requiring that qualifying and aggravating circumstances be alleged in the information (Section 9, Rule 1...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)