G.R. No. L-45966 - People vs. Mariano y Alejandro

The accused, Mario Mariano y Alejandro alias Negro, was charged with the crime of rape with homicide.
The offense involved the sexual assault and subsequent death of a minor, Luningning Mapola, aged six, in Manila on November 11, 1976.
The charges and facts were set forth in the Information, which described the use of force, violence, and intimidation by the accused.

According to the Information, the accused “wilfully, unlawfully and feloniously” pinned down the victim, used force to silence her, and had carnal knowledge with her.
The victim suffered traumatic lacerations of the vagina and significant head injuries resulting in profuse hemorrhage and death.
The description of the victim’s state—found with rolled-up dress, swollen eyes due to blood volubly exuding—underscored the brutality and fatal consequences of the crime.

Upon arraignment on November 19, 1976, the accused was informed of the charge after the Information was translated into Tagalog.
Assisted initially by counsel de oficio, he voluntarily and spontaneously entered a plea of guilty, even after being warned that the maximum penalty was death.
Later, he was represented by counsel de parte, Atty. Narciso Santiago, who confirmed that the accused had a clear understanding of the charges and the consequences of his plea.

Juanita Mapola, the adoptive mother of the victim, who recounted how the victim was found dead in an uninhabited house in Tondo, Manila.
Rebecca Molina, a 13-year-old student, who testified to an earlier incident involving the accused’s conduct.
Santiago Vargas, a patrolman, who testified regarding the investigation including the accused’s extra-judicial written confession and re-enactment of the crime.
Luis Larion, a medico legal officer, who provided autopsy findings establishing the cause of death.

The accused’s birth certificate and marriage contract, establishing his identity and civil status.
Testimonies from further defense witnesses, such as Angelo Singian and Cesar Villanueva, corroborated the physical evidence and timeline of the incident.

The accused’s verbal admissions during court proceedings, including detailed dialogue with the trial judge, confirmed both his awareness and understanding of the charge:

The accused affirmed knowing that his guilty plea equated to an admission of committing rape with homicide.
He acknowledged the severity of the potential sentence, even when cautioned about the imposition of the death penalty.

To clarify the legal status of the accused, the trial court reopened the case on December 13, 1976, to verify his marital status, which proved material to the application of relevant laws.
Several trial dates were reset to accommodate additional evidence and witness testimonies, culminating in a comprehensive hearing that covered both the substantive charges and procedural safeguards.
The court’s detailed inquiries and explanations ensured that the accused was fully apprised of the nature of the case and the legal consequences of his plea.

The accused admitted that his actions were partially influenced by his state as an addict, claiming he was “not in his right senses” during the incident.
Despite this admission, evidence confirmed that the physical acts during the commission of the crime were deliberate and matched the forensic findings.
The case record included extensive dialogue and inquiry that refuted the argument that his plea was entered without full comprehension.

Whether the trial court erred in accepting the plea of guilty without a more thorough inquiry into the circumstances surrounding the plea and whether the accused fully understood its implications.
Whether the accused’s informed and voluntary plea of guilty, confirmed through repeated judicial questioning, could be deemed sufficient given the gravity of the charge (rape with homicide).
Whether the extra-judicial confession, supported by corroborative physical and testimonial evidence (proof of corpus delicti), provided a sound basis for convicting the accused.
Whether mitigating circumstances, such as the accused’s drug addiction and his claim of not intending to kill the victim, could or should have influenced the sentence, especially in light of the mandatory nature of the death penalty under Article 335 of the Revised Penal Code.
Whether the cumulative evidence, despite the accused’s explanation and mitigating factors, sufficiently established his criminal liability beyond reasonable doubt.