Case Digest (G.R. No. 67662)
Case Digest (G.R. No. 67662)
Facts:
People of the Philippines v. Marcos Manalang y Taguinod, G.R. No. 67662, February 09, 1989, Supreme Court Second Division, Sarmiento, J., writing for the Court.The accused-appellant, Marcos Manalang y Taguinod, a 20‑year‑old cousin of the husband in the household, resided with the Lorenzo family in Lagro Subdivision, Novaliches. Marcos formed a love relationship with Maggie Chavez and, having fallen into neglect of his studies and fear of losing Maggie’s affection, decided on January 2–3, 1984 to eliminate members of the Lorenzo household whom he viewed as obstacles. On January 3, 1984 he stabbed and/or bludgeoned to death Felisa Capalungan (Maximino Lorenzo’s 69‑year‑old mother), two children (Carlomax and Lawrence), and the househelp Zenaida Nicobeza; he then took money, jewelry and other personal property and departed the house.
Marcos fled, wrote several admissions/confessions and letters confessing to the crimes, and on January 13, 1984 surrendered in Solana, Cagayan. He executed two extrajudicial confessions (Tuguegarao, Jan. 14, 1984; Quezon City Police, Jan. 16, 1984) and repeated the confession in court; he also surrendered some of the stolen property and the revolver. An Information dated January 17, 1984 filed in the Regional Trial Court (RTC), Branch LXXXIX, Quezon City charged him with the special complex crime of Robbery with Multiple Homicide (Article 294(1), Revised Penal Code), alleging killings qualified by premeditation and treachery and an intent to rob.
At arraignment the accused admitted the killings but — because the Information charged the complex crime — the trial court entered a plea of not guilty and proceeded to trial. The RTC concluded the original design was to kill, not to rob, and that the taking of property was an afterthought. The trial court convicted Marcos instead of four (4) separate counts of Murder (with attendant aggravating circumstances) and a separate count of Theft, sentencing him to death for each murder and to an indeterminate prison term for theft; the trial court also awarded indemnities and moral damages. The RTC decision was rendered March 28, 1984 by Judge Rodolfo Ortiz.
The case reached the Supreme Court on automatic review (the trial court had imposed the death penalty), and the Supreme Court Second Division affirmed conviction but, invoking the 1987 Constitution’s prohibition on the imposition of death, converted each death sentence to reclusion perpetua and adjusted indemnities.
Issues:
- Can the accused be validly convicted of four separate counts of Murder and a separate Theft when the Information charged Robbery with Multiple Homicide under Article 294(1) RPC?
- Is the Information fatally defective because it used the designation "Robbery with Multiple Homicide" (a term not literally in the Revised Penal Code)?
- May the death penalty imposed by the trial court be carried out in view of the 1987 Constitution?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)