Case Digest (G.R. No. L-63251-52)
Facts:
People of the Philippines v. Alexander de la Fuente y Mahilum, G.R. Nos. 63251-52, December 29, 1983, the Supreme Court En Banc, Aquino, J., writing for the Court. This case is a review en consulta of the judgment of the Court of First Instance of Zamboanga del Norte, Dipolog City Branch I, which convicted Alexander M. de la Fuente of the "complex offense of double murder with frustrated murder," sentenced him to death, and ordered indemnities of P12,000 to each set of heirs of the deceased (Criminal Cases Nos. 2969 and 2970).The accused, then 21, was charged separately with double murder (for killing his common‑law wife Elvira B. Dumapig and her mother Matilde B. Dumapig) and with frustrated murder (for wounding Imelda B. Dumapig). The prosecution's primary evidence was an extrajudicial confession (Exh. A) which De la Fuente ratified on the witness stand; he also entered a plea of guilty at arraignment. The trial judge nonetheless required the prosecution to present its evidence to determine both guilt and penalty.
Prosecution witnesses included eyewitness Imelda (then 16), a hospital physician, Alejandro Dumapig (Matilde’s husband), and a police intelligence officer who helped in the accused's surrender. The factual account was that on the night of September 21, 1982, while Elvira and Matilde were asleep in Matilde’s house in Barangay Olingan, Dipolog City, De la Fuente entered and stabbed both women fatally; Imelda, awake and combing her hair, saw the attack, escaped through a window, and was stabbed on the buttock. The victims’ autopsies showed penetrating chest wounds affecting heart and lungs. De la Fuente surrendered to local authorities shortly after.
At arraignment on November 23, 1982, De la Fuente initially answered affirmatively that he understood the information but then pleaded guilty to the murder informations and to the frustrated murder information; the trial judge informed him of the capital nature of the charges and the possible death penalty. At trial the accused testified in mitigation, alleging provocation (a dispute over P20 and that Elvira bit him hours earlier) and claiming the stabbing of Imelda was accidental in the darkness. The trial court disbelieved his testimony, found treachery, nocturnity, evident premeditation and dwelling as aggravating circumstances for the murders, and assessed the death penalty while awarding P12,000 indemnity to each set of heirs and P5,000 to Imelda.
On automatic review, counsels de oficio urged that the murders be treated as homicides or as a complex crime and that passion and obfusc...(Subscriber-Only)
Issues:
- Is the accused’s extrajudicial confession admissible and did his plea of guilty operate as a judicial confession removing doubt as to guilt?
- Were the killings properly treated as a complex offense of double murder with frustrated murder, or as separate offenses (two murders and an attempted murder)?
- What are the proper legal characterizations of the killings and the attendant aggravating or mitigating circumstances, and what penalties should be imposed?
- Should the civil indemn...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)