Case Digest (G.R. No. 122485)
Facts:
People of the Philippines v. Larry Mahinay y Amparado, G.R. No. 122485, February 01, 1999, the Supreme Court En Banc, Per Curiam. The prosecution (the People of the Philippines) charged Larry Mahinay y Amparado (appellant) with rape with homicide in an Information filed in the Regional Trial Court (RTC), Valenzuela (Criminal Case No. 4974‑V‑95). The RTC found appellant guilty beyond reasonable doubt, sentenced him to death, and awarded indemnity and funeral expenses to the victim’s heirs. Pursuant to Article 47 of the Revised Penal Code as amended by R.A. No. 7659, the case was forwarded to the Supreme Court for automatic en banc review.The victim, Ma. Victoria Chan, was a 12‑year‑old girl whose naked, bruised body with hymenal lacerations was recovered from a septic tank on June 26, 1995. Evidence at trial included eyewitness accounts placing appellant in and around the crime scene on the evening of June 25, 1995; identification of the victim’s clothing and other personal effects found in the house where appellant slept; the autopsy findings (cause of death: asphyxia by manual strangulation, with traumatic head injury as contributory, and genital lacerations consistent with penile penetration); and appellant’s extra‑judicial confession describing sexual intercourse and disposal of the body.
Appellant testified at trial offering an alternative story: that two other men (Zaldy and Boyet) brought a cadaver to the upstairs room where he was sleeping, forced him at knife point to rape the dead body, and compelled him to assist in dumping the corpse; he also claimed his extra‑judicial confession was made under duress and while he was denied counsel. The police apprehended appellant in Batangas; a Public Attorney’s Office lawyer signed and testified to having warned and advised appellant of his constitutional rights and to appellant’s voluntary execution of the written confession and waiver.
On automatic review the Supreme Court considered (inter alia) whether the circumstantial and direct evidence and the extra‑judicial confession established guilt beyond reasonable doubt, whether appellant’s age barred imposition of death, and the...(Pro-only)
Issues:
- Was the circumstantial and other evidence sufficient to convict appellant of rape with homicide beyond reasonable doubt?
- Was appellant’s extra‑judicial confession admissible, or was it rendered involuntary by violation of his constitutional right to counsel?
- Was the death penalty properly imposed (including whether appellant was under eighteen at the time of the offense)?
- What civil damages and procedure on automatic ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)