G.R. No. 144907-09 - People vs. Gutierrez

On 20 June 1999, Venus Ramos visited her sister, Analiza de la Cruz, at their family compound located in Tibag, Baliuag, Bulacan.
The family compound housed a two‐storey ancestral home where another sister, Lorelie de la Cruz, resided next door with their cousin, Manuel Gutierrez.

Around 2:30 in the afternoon, while watching television, Venus Ramos heard noises from the second floor of the ancestral home.
Rushing upstairs, she encountered a gruesome scene where her sister, Lorelie, was being stabbed from behind by Manuel Gutierrez.
Terrified by the unfolding events, Venus retreated to the ground floor and met her other sister, Analiza de la Cruz.
Upon learning of the violent assault, Analiza immediately returned to her own house for safety.

While Venus ran towards the gate of the compound to seek help from neighbors, she saw Manuel Gutierrez stabbing a second victim—Rializa Trabel.
The accused then attacked Lilian Trabel, Rializa’s mother, striking her on the ear with a kitchen knife.
Lilian Trabel managed to evade further harm by seeking refuge inside her house, though she sustained injuries.
Tragically, both Lorelie de la Cruz and Rializa Trabel died before receiving any medical attention.

Manuel Gutierrez was arrested a few hours after the incident.
He was charged with double murder (for the deaths of Lorelie and Rializa) and with attempted murder (for wounding Lilian Trabel).
Initially, the accused pleaded “Not Guilty” but switched his plea to “Guilty” after the prosecution had presented its first witness.
Before accepting the plea, the trial court verified that the accused fully understood the meaning and consequences of his plea of guilt, to which he explained his desire to grant his relatives serenity and peace of mind.

Lilian Trabel provided a detailed, emotionally charged account of the attack on her daughter, Rializa, describing how Rializa was awoken by a noise and then suddenly attacked by Manuel Gutierrez, who stabbed her on the head with a kitchen knife.
The trial court noted the presence of treachery in the killing of Lorelie de la Cruz because the victim was attacked from behind with the assailant holding her hair, and the assault occurred in her own home, making it sudden and unexpected.
Similarly, treachery was noted in the killing of Rializa Trabel as the victim had no opportunity to defend herself.
For the assault on Lilian Trabel, however, the court categorized her injuries as serious physical injuries, though her wounds were later shown to require only a month’s healing time.

Manuel Gutierrez was sentenced twice to suffer the penalty of death for the killings of Lorelie and Rializa.
Additionally, he was sentenced to an indeterminate prison term ranging from four (4) months of arresto mayor (as minimum) to two (2) years and four (4) months of prision correccional (as maximum) for the assault on Lilian Trabel.
He was ordered to indemnify the heirs of Lorelie and Rializa with P100,000.00 and Lilian with P5,000.00 as actual damages.

The case was elevated to the Supreme Court on automatic review because of the imposed penalty of death.
Although the accused did not deny his guilt, he challenged the trial court’s appreciation of treachery as an aggravating circumstance, arguing that:

Venus Ramos, the key witness, did not witness the commencement of Lorelie’s stabbing, thereby weakening the prosecution’s claim of treachery.
The stabbing of Rializa was a result of a momentary impulse rather than a calculated act warranting treachery.

The Solicitor General argued that the accused’s plea of guilt constituted a judicial confession of all material facts, including the aggravating circumstances.
The Supreme Court, however, revisited prior rulings stating that a guilty plea does not automatically admit the aggravating circumstances unless supported by evidence.
This principle was underscored by references to People v. Derilo and other cases, highlighting that an accused may plead guilty to the act without understanding or intending to confess to the attendant aggravating circumstances.

Whether the evidence was sufficient to sustain the finding of treachery in the conduct of Manuel Gutierrez, specifically concerning:

The killing of Lorelie de la Cruz, given that the witness did not see the complete sequence of the attack.
The killing of Rializa Trabel, where the assault appeared to be impulsive without prior planning.

Whether the plea of guilt should be deemed as an unconditional admission of all the aggravating circumstances alleged in the Information.

To what extent can an accused’s plea of guilt be said to encompass technical elements such as treachery, especially when those elements are beyond the ordinary understanding of a layperson.
Whether the trial court’s reliance on the plea of guilt in establishing treachery is legally tenable.

Whether the injury should be considered “serious physical injuries” given that the healing period stated in the medical certificate was one month (interpreted as 30 days under Article 13 of the Civil Code), pointing rather to less serious physical injuries.