Case Digest (G.R. No. 227021)
Facts:
In People of the Philippines v. Larry Mahinay y Amparado, appellant was employed as a houseboy by Maria Isip beginning November 20, 1993, to care for her unfinished residence in Gen. T. de Leon, Valenzuela, Metro Manila. The victim, 12-year-old Ma. Victoria Chan, was Isip’s neighbor who frequently played in the compound. On June 25, 1995, after a drinking spree, Mahinay failed to return home. Early the next morning, passersby recovered the girl’s naked body from the septic tank on Isip’s premises. A medico-legal autopsy disclosed manual strangulation, traumatic head injury, and hymenal lacerations consistent with penile penetration. Investigators found the victim’s clothes and the houseboy’s belongings in the unfinished structure. Following inquiries and leads to Batangas, police arrested Mahinay on July 7, 1995. He executed an extrajudicial confession with the assistance of PAO counsel, admitting he raped and killed the child. The Regional Trial Court of Valenzuela convicted hiCase Digest (G.R. No. 227021)
Facts:
- Background
- Appellant Larry Mahinay y Amparado was employed as houseboy by Maria Isip since November 20, 1993 and lodged in an apartment adjacent to an unfinished house in Valenzuela, Metro Manila.
- Victim Ma. Victoria Chan, 12 years old, lived nearby and habitually played within Isip’s compound.
- Events of June 25–26, 1995
- Morning–afternoon of June 25: appellant joined a drinking spree, then left the compound; victim seen alone in the unfinished house yard.
- Evening of June 25: appellant appeared disheveled and uneasy in a store facing the compound; later he did not return to his lodging.
- Early morning of June 26: appellant fled via jeepney to Batangas; later that morning at about 7:30 a.m., resident “Boy” discovered victim’s body in the septic tank.
- Investigation and Evidence
- Autopsy findings: asphyxia by manual strangulation; traumatic head injury; multiple contusions and abrasions; hymen lacerations consistent with penile penetration.
- Crime-scene evidence: victim’s clothing in the unfinished house; appellant’s belongings (slippers, clothes, wallet, pliers) found near the septic tank.
- Apprehension and confession: arrested July 7, 1995 in Batangas; executed an extrajudicial confession detailing rape and strangulation, with counsel from the Public Attorney’s Office present.
- Trial Court Proceedings
- Information for rape with homicide filed July 10, 1995; appellant pleaded not guilty.
- After trial, the Regional Trial Court convicted him of rape with homicide, sentenced him to death by electric chair, and ordered indemnity of ₱50,000 plus ₱23,000 for funeral expenses.
Issues:
- Whether the circumstantial evidence presented sufficed to establish appellant’s guilt beyond reasonable doubt.
- Whether the extrajudicial confession was voluntarily given and properly admitted.
- Whether appellant’s story of coercion by third parties to rape a cadaver was credible.
- Whether the death penalty and indemnity awards were correctly imposed under the applicable law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)