G.R. No. 128338 - Resuena vs. Court of Appeals

On the evening of September 21, 1984, Mercedes M. Dulay, a 29-year-old registered nurse, was brutally raped, murdered, and robbed in Barangay Inamotan, Manaoag, Pangasinan.
While quietly traversing the barrio road on her way home, Mercedes became the victim of a heinous crime that involved multiple assailants, leading to her suffering a series of stab, hack, and rape injuries.

The accused—Leonardo Flores, Alex King Cruz, Servillano Parinas, and Ernesto Sarsoza—conspired and executed the crime in a premeditated manner.
Prior to the crime, Flores, Cruz, Parinas, and Sarsoza, along with other companions, met at the house of a friend (Jose Cacayan), where they drank white rum, smoked marijuana, and later reconvened to plan their criminal act.
At the Samiley irrigation site, approximately fifty meters from Cacayan’s house, the conspirators ambushed Mercedes who was returning alone, thereby employing superior strength and taking advantage of the darkness.

Flores caught the victim by placing his arm around her neck while Cruz and the others forcefully restrained and assaulted her.
Cruz actively tore apart her garments with a bayonet while the others alternated in raping her.
Despite pleas from Mercedes to spare her life in exchange for her valuables, the assailants decided to kill her, with Cruz finally slashing her neck.

In a final act of cruelty, after she was silenced, Sarsoza stabbed her breast with his bayonet and, upon a command, Flores inserted a branch of ipil-ipil wood into her vaginal canal.
Post-assault, the perpetrators asported specific belongings: Flores retrieved a gold graduation ring (later partially altered), a lady Seiko wrist watch, and cash was taken from the victim’s belongings.

Leonardo Flores, who initially pleaded guilty, eventually provided a detailed judicial confession in open court which implicated his co-accused. His testimony was thorough, recounting the events before, during, and after the crime.
Forensic evidence included:

Autopsy reports from two separate examinations (by the rural health unit physician and by Dr. Arturo G. Llavore) indicating massive hemorrhage due to multiple stab and hack wounds, and the presence of the ipil-ipil branch in the vaginal canal.
Recovery of physical evidence such as a blood-stained bayonet, the victim’s graduation ring, and other personal belongings.
Comparative forensic examinations of hair specimens which indicated the involvement of several persons.

Witness testimonies included statements from members of the victim’s family, who provided context regarding her daily routine and the financial implications of her loss.

Defendants Cruz, Parinas, and Sarsoza interposed an alibi claiming they were with other acquaintances watching television and socializing at different locations during the time of the crime.
Their alibi was largely supported by testimonies of relatives whose credibility was later questioned due to possible bias.
The lower court, after a full trial, found all accused guilty of the special complex crime of multiple rape with homicide (and an ancillary crime of theft regarding the victim’s belongings), imposing four death penalties on each accused based on the elements of conspiracy, premeditation, and aggravating circumstances.
Upon appeal, while Leonardo Flores withdrew his appeal opting to accept reclusion perpetua, the other three continued with their appeal despite arguments that the conviction rested primarily on Flores’ judicial confession.

Whether the judicial confession of Leonardo Flores, given in open court and implicating his co-accused, was sufficiently reliable and admissible, despite his earlier extrajudicial confession not being assisted by counsel.
The legal distinction between judicial and extrajudicial confessions and its bearing on the guilt of the co-accused.

Whether the evidence, particularly Flores’ detailed judicial confession combined with the coordinated manner of the crime’s execution, adequately established the conspiracy among the accused.
Whether the cooperative and sequential acts during the commission of the crime sufficed to prove a joint conspiracy.

Whether the evidence overall (including forensic reports, testimonies, and physical evidence) was sufficient to convict the accused of multiple rape with homicide.
The reliability of the alibi defense and testimonial discrepancies, especially given the involvement of relatives in supporting the appellants’ version.

Whether the imposition of the death penalty, later converted to reclusion perpetua pursuant to the 1987 Constitution’s abolition of capital punishment, was correctly applied.
The appropriateness of the sentence for the separate crime of theft in the context of the committed offense.

Whether the taking of the victim’s belongings (the ring, watch, and cash) should be considered an independent crime or merely an afterthought in the commission of the heinous primary crime.