Case Digest (G.R. No. 144907-09)
Facts:
People of the Philippines v. Manuel Gutierrez, G.R. Nos. 144907-09, September 17, 2002, the Supreme Court En Banc, Bellosillo, J., writing for the Court.On 20 June 1999, Venus Ramos visited her sister Analiza de la Cruz at the family compound in Tibag, Baliuag, Bulacan. Venus’s other sister Lorelie de la Cruz lived next door with their cousin, accused Manuel Gutierrez, and a cousin Rializa Trabel and her mother Lilian Trabel lived nearby. At about 2:30 p.m. Venus heard noises from the second floor, ran upstairs, and saw Manuel stabbing Lorelie from behind; she retreated, met Analiza, and sought help. Venus also saw Manuel stab Rializa and strike Lilian on the ear with a kitchen knife. Rializa and Lorelie died before receiving medical attention; Lilian survived with injuries.
Manuel was arrested hours later and charged with two counts of murder (for Lorelie and Rializa) and attempted murder/physical injuries for the assault on Lilian. He pleaded not guilty initially but, after the prosecution’s first witness testified, changed his plea to guilty. The trial court inquired into his understanding of the plea and, satisfied, accepted it but proceeded to receive prosecution evidence to determine the proper penalty in accordance with Rule 116, Sec. 3.
At trial, the court a quo found treachery attending the killings (Lorelie was stabbed from behind while the assailant held her hair; Rializa was said to have been attacked while unsuspecting) and convicted Manuel of two counts of murder and one count of serious physical injuries for the assault on Lilian, sentencing him to death twice, plus an indeterminate term for the physical injuries, and ordering indemnities. The cases were elevated to the Supreme Court on automatic ...(Subscriber-Only)
Issues:
- Does a formal plea of guilty constitute an admission of attendant aggravating circumstances, specifically treachery?
- Was the killing of Lorelie de la Cruz attended by treachery?
- Was the killing of Rializa Trabel attended by treachery?
- Do Lilian Trabel’s injuries constitute serious physical injuries or less serious physical injuries ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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