Case Digest (G.R. No. 168301)
Facts:
The People of the Philippines prosecuted Romeo Manalang y Ocon for four killings occurring on August 11, 1977 at the Shih residence in Plainview, Mandaluyong, where Maria Lourdes Shih, Rosita Shih, Joy Angelique Shih (age five) and housemaid Hilda Pomida were found fatally stabbed; necropsies showed multiple stab wounds. Manalang was arrested August 12, 1977 in Paranaque with items taken from Maria Lourdes, executed a six‑page extrajudicial confession, reenacted the crimes, pleaded guilty with court‑appointed counsel, and the Circuit Criminal Court of Rizal sentenced him to death in each of the four murder cases with accessory indemnities and damages; the case came to the Court on mandatory review.
Issues:
- Did the evidence establish Manalang’s guilt beyond reasonable doubt for the killings?
- Was the extrajudicial confession admissible under Section 20, Article IV of the Constitution given the absence of counsel and the warnings given?
- Did the trial court err in refusing to permit the accused to testify to prove insanity and thereby withdraw his plea of guilty?
Ruling:
The Court affirmed the convictions and sentences with modifications: it affirmed the death penalty for the murders of Rosita Shih and Maria Lourdes Shih, sentenced Manalang to reclusion perpetua for the murder of Joy Angelique Shih, and convicted him of homicide as to Hilda Pomida with a penalty of twelve years prision mayor minimum to seventeen years and four months reclusion temporal maximum; costs de oficio were imposed. The Court held the trial court did not err in denying the accused’s offer to testify to prove insanity while maintaining his guilty plea.
Ratio:
The Court found guilt established by the eyewitness identification, possession of the victim’s belongings at arrest, the detailed extrajudicial confession corroborated by physical facts and necropsy reports, and the reenactment, all proving authorship and circumstances beyond reasonable doubt. The Court analyzed qualifying and aggravating circumstances: it upheld treachery (except as to Hilda), dwelling as aggravating, and evident premeditation as present for Rosita and Maria Lourdes; it treated the plea of guilty as a mitigating circumstance and applied Art. 12, Revised Penal Code to reject the insanity defense for lack of proof of total deprivation of reason and will.
Doctrine:
- A voluntary plea of guilty is a mitigating circumstance and may waive objections to the admissibility of prior statements.
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