Case Digest (G.R. No. 241034)
Facts:
The case revolves around Marcos Manalang y Taguinod (the accused-appellant) who committed a horrific crime on January 3, 1984, at the residence of his cousin, Maximino Lorenzo, in Novaliches, Quezon City. The family comprised Maximino, his wife Edith Bolivar-Lorenzo, their two children Carlomax and Lawrence, and Felisa Capalungan Vda. de Lorenzo, the elderly mother of Maximino. Marcos had been living with the family since being invited by Maximino for support during his college years. After dropping out of school, the appellant became infatuated with a neighbor named Maggie Chaves. His obsession grew, leading him to feel desperate about maintaining both his relationship with Maggie and his benefactor's trust.
On the day of the crimes, following a night of contemplation on January 2, 1984, Marcos plotted to murder the entire Lorenzo family, viewing them as obstacles to his affair with Maggie. Armed with a kitchen knife and a hammer, he first killed Felisa, stabbing her afte
Case Digest (G.R. No. 241034)
Facts:
- Background and Relationship
- Marcos Manalang, a 20-year‑old relative of the Lorenzo family, was initially employed by Engineer Maximino Lorenzo on a government project and was later taken in by the Lorenzos.
- The Lorenzos, comprising Maximino, his wife Edith Bolivar-Lorenzo, their two young sons (Carlomax and Lawrence), Maximino’s 69‑year‑old mother Felisa Capalungan Vda. de Lorenzo, and other household members (including the 19‑year‑old househelp Zenaida Q. Nicobeza), treated Marcos as a son by providing for his needs and even sponsoring his college education.
- During his stay, Marcos became acquainted with Maggie Chavez, a young lady residing in the same subdivision, with whom he entered a passionate and ultimately destructive love affair.
- Marcos’ infatuation with Maggie led him to neglect his academic pursuits and misuse the financial support provided by his cousin Maximino, thereby creating an internal conflict and mounting desperation.
- Escalation and Precipitating Factors
- Marcos became aware that he was deceiving Maximino by using the funds meant for his education for personal indulgences and his relationship with Maggie.
- Overwhelmed by guilt and anxious about the possible loss of Maggie’s affection if his deception was discovered, Marcos sank into a state of desperation.
- In a fit of resolve one evening on January 2, 1984, while still in bed, he committed himself to a diabolical scheme for eliminating all members of the Lorenzo household whom he saw as obstacles to his relationship with Maggie.
- Execution of the Crimes
- On the morning of January 3, 1984, after Maximino and Edith had left for work, Marcos orchestrated his plan:
- He first dispatched the househelp, Zenaida Nicobeza, by sending her out with a P20.00 errand.
- Armed with a kitchen knife, hammer, and butcher’s knife, he entered the residence and committed the murders.
- The sequence of the killings was as follows:
- In the room of his aunt, Felisa Capalungan Vda. de Lorenzo, he attacked her from behind with a kitchen knife despite her pleas for mercy.
- Proceeding to the master bedroom, he smothered Carlomax Lorenzo (suffering from measles) by covering his mouth with a pillow before repeatedly stabbing him.
- He then attacked Lawrence Lorenzo in a similar manner; during the process, the kitchen knife broke and injured Marcos’ hands.
- Upon the return of Zenaida, he struck her with a hammer and then killed her using a butcher’s knife.
- After the murders, he dragged and piled the bodies of the victims in the room where Felisa had been killed, and in an attempt to cover up his crimes, he wiped away the blood stains.
- Post-Crime Actions and Fleeing
- Marcos attempted to cover his traces and secure funds for his escape by:
- Washing and tending to his wounds.
- Searching the house for any available money and personal property; he took cash (amounting to P300.00 in total), pieces of jewelry, and a caliber .22 magnum Arminius revolver.
- He used Maximino’s bicycle initially and sought medical treatment at various facilities, switching from one establishment to another, including the Lagro Health Center, MCU Hospital, and Quezon City General Hospital.
- Despite considering further violence (planning to kill the Lorenzo couple with a bolo), at one point he had a change of heart and decided to flee through back exits, jumping over a fence with the assistance of a neighbor.
- Confession, Letters, and Surrender
- While in hiding in Baguio City at the Emerald Lodge, Marcos grappled with his actions and his emotional devastation upon learning that Maggie had distanced herself from him.
- In a state of desperation, he composed several letters:
- One letter to Capt. Jil Fabian admitting his murderous act and recounting his love affair with Maggie.
- Additional letters addressed to Mrs. Chavez and Maggie professing his love and confessing his intent to kill those who impeded their relationship.
- On January 13, 1984, accompanied by his brother and uncle, Marcos surrendered in Solana, Cagayan, to Mayor Alexander Balauitan and subsequently to Minister Juan Ponce Enrile.
- During custodial investigations at various police stations, he reiterated his confessions both in writing and orally, admitting to the killing of Felisa, Carlomax, Lawrence, and Zenaida, as well as to the robbery of property from the Lorenzo residence.
- Filing of Charges and Trial Court Proceedings
- An Information was filed on January 17, 1984, before the Regional Trial Court in Quezon City charging Marcos with the complex offense of Robbery with Multiple Homicide.
- Although he admitted to the killings and certain acts of theft, Marcos contested that his original intent had been solely to murder, thereby asserting that the theft was an afterthought.
- Based on the evidence and his multiple extrajudicial confessions, the trial court found that:
- The killing was premeditated, executed with treachery and cruelty.
- The theft was incidental and not the primary objective of the criminal design.
- Consequently, the court convicted him of four separate crimes of Murder and an additional distinct offense of Theft.
- Sentencing and Subsequent Review
- The trial court’s decision sentenced Marcos to suffer the death penalty for each of the four counts of Murder (with accessory penalties and indemnification orders) and an indeterminate period of imprisonment for Theft.
- On automatic review by the appellate court, while affirming the conviction for the murders and the theft, the death penalty was replaced by reclusion perpetua in light of the 1987 Constitutional prohibition.
- The decision ultimately confirmed his guilt beyond reasonable doubt, setting aside his contention regarding the complex nature of the charged offense.
Issues:
- Nature of the Criminal Design
- Whether Marcos’ original criminal intent was to commit robbery with homicide or solely to murder the members of the Lorenzo family.
- Whether the taking of personal property was a primary aim or merely an afterthought to provide funds for escape.
- Validity of Charging and Conviction
- Whether the information charging him with Robbery with Multiple Homicide—a complex crime not clearly defined in the Revised Penal Code—is valid.
- Whether convicting him separately of four counts of Murder and one count of Theft is consistent with the evidence and legal principles.
- Admissibility and Impact of Confessions
- The weight and consistency of the extrajudicial confessions in corroborating the sequence of events.
- Whether his written letters and post-crime conduct effectively establish the separate elements of murder and theft beyond reasonable doubt.
- Consideration of Aggravating and Mitigating Circumstances
- Whether the presence of multiple aggravating circumstances (evident premeditation, treachery, abuse of confidence, and cruelty) outweighed the single mitigating circumstance of voluntary surrender.
- How these circumstances influenced the imposition of penalties.
- Procedural and Substantive Challenges
- Whether any error in the designation or interpretation of the charged offense (the use of “multiple” in the crime of Robbery with Multiple Homicide) warrants reversal of the conviction.
- Whether the accrual of distinct offenses within one framework of charge was appropriately handled pursuant to established legal rules.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)