G.R. No. L-46146 - People vs. Laspardas

On December 1, 1976, in Sitio San Roque, Barrio Pagalongan, Wao, Lanao del Sur, Laurencio Laspardas allegedly committed double murder with treachery and evident premeditation.
The victims were the minor sisters Elizabeth Arriesgado (12 years old) and Josephine Arriesgado (8 years old).
The complaint initially filed on December 17, 1976 by a Constabulary sergeant against Laspardas in the municipal court of Wao charged him with double murder. Later, because of his admission of having raped one victim, the charge was amended to include rape with homicide.

Bibiana Arriesgado, who was related to the victims, attested to having left the children in the care of Laspardas.
Vicente Magdaloyo, a local resident, testified that the crimes occurred in the victims’ house and that Laspardas sought a repayment shortly after the incident.
Armando Ortanillas, a neighbor, purportedly witnessed Laspardas with the victims on the afternoon of December 1, 1976.
Additional statements from other community members corroborated the sequence and details of the crime.

Following the issuance of a municipal warrant, Laspardas was arrested on December 10, 1976 at Cabadbaran, Agusan Norte.
An extrajudicial confession was taken from him; the interrogation was conducted in Cebuano, and his responses were later translated into English. His confession included:

Admission of killing the Arriesgado sisters with a locally known Tabas or sundang knife.
Admission that, while one of the victims was dying, he perpetrated an act of sexual abuse on Elizabeth Arriesgado, describing explicit details of the act.
Assertions that his motive stemmed from anger over unpaid wages owed by the Arriesgado spouses, for whom he had worked for two years as a farmhand.

At arraignment in the municipal court and subsequently in the Court of First Instance, Laspardas pleaded guilty after being informed of his rights, with assistance from counsel de oficio.
The trial record reflects a comprehensive presentation of evidence, including the accused’s confession, witnesses’ testimonies, and other material evidence which left little doubt as to his culpability.

The accused’s statements during interrogation were clear and voluntary, having been made with full understanding of his rights under the New Constitution.
Both his extrajudicial confession and his later testimony in court confirmed the details and circumstances of the crime, from the planning to its execution.
The intensity of premeditation was evident through:

The planning mentioned in his confession about raping Elizabeth and murdering Josephine at a specific time on December 1, 1976.
His lack of remorse and deliberate act of killing the children driven by personal grievance against their parents.

Counsel de oficio later raised issues regarding the accused’s plea, claiming it might have been improvident given his educational background; however, the overall record provided a firm basis for the conviction.

Whether the trial court erred in convicting Laurencio Laspardas for rape with homicide when the original information presented three distinct offenses (rape and two separate murders).

The charge was elevated on the basis that the sexual abuse of Elizabeth occurred during the commission of the murders, raising questions about the proper classification of the crime.

Whether the wrongful use or the sufficiency of the accused’s extrajudicial confession should affect the conviction, especially regarding its voluntariness and his full knowledge of the rights and consequences.

The admissibility and weight of the extrajudicial confession, although not formally presented in evidence, were upheld by his subsequent plea and testimony.

Whether the mitigating circumstance (plea of guilty, attributed to passion or lack of education) could diminish the impact of the aggravating circumstances such as treachery, evident premeditation, and abuse of confidence.

The issue also involved assessing if the mitigating factors could offset both aggravating circumstances or just one, given that one of the victims also suffered an act of ignominy or cruelty.

Whether treating the rape as an independent offense or as an aggravating circumstance to the murders was consistent with precedent and the proper application of Article 335 of the Revised Penal Code.