Title
People vs. Muleta
Case
G.R. No. 130189
Decision Date
Jun 25, 1999
Domingo Muleta was acquitted of rape with homicide after the Supreme Court ruled his extrajudicial confession inadmissible due to lack of proper legal safeguards and insufficient circumstantial evidence.

Case Digest (G.R. No. 130189)
Expanded Legal Reasoning Model

Facts:

  • Parties and Charge
    • Domingo R. Muleta (appellant) was charged with the complex crime of rape with homicide for the death of Charito M. Delgado, his niece.
    • The Information alleged that on April 30, 1993, Muleta forcibly had carnal knowledge of Delgado while she was unconscious and subsequently stabbed her, causing immediate death.
    • Muleta pleaded not guilty at his arraignment.
  • Circumstances Leading to the Case
    • Charito Delgado, age nineteen and from Oriental Mindoro, went to Manila for work, staying with relatives and working as a saleslady.
    • She was last seen alive on April 29, 1993; her body was found naked, tied, and with multiple stab wounds in Malolos, Bulacan on April 30, 1993.
    • The initial investigation was by the Malolos police, later taken over by the NBI and assigned to Agent Ely Tolentino.
    • Appellant was identified as Charito’s maternal uncle and was working at Loadstar Shipping Lines at the time.
    • Appellant was asked by NBI to accompany them for investigation on September 19, 1993, where he was allegedly assisted by counsel Atty. Deborah Daquiz.
    • During custodial investigation, appellant allegedly confessed to committing the crime.
    • Witness Danilo Delgado testified about appellant’s hysterical conduct and mutterings of apology during the victim’s wake, and subsequent ingestion of "chlorox" followed by hospitalization.
  • Defense Version
    • Appellant denied committing the crime, claiming he was forcibly picked up and tortured by NBI agents to extract a confession.
    • He claimed presence at his rented house on the night of April 29 and early April 30, 1993, and that he reported the victim missing to the police before the body was found.
    • He admitted visiting the victim's house on April 26, 1993, but denied any contact afterwards.
    • His wife corroborated his alibi, saying he never left their house that evening.
    • He denied working in Malolos and explained his strange behavior during the wake as grief and inability to protect his niece.
  • Trial Court Decision
    • Despite no eyewitness, the RTC convicted appellant of rape with homicide based on circumstantial evidence and extrajudicial confession.
    • The court cited appellant’s knowledge of the crime scene, work absences coinciding with the crime, his words during the wake, admission of drinking "chlorox," and the detailed confession as proof.
    • The trial court ruled the confession was voluntary and assisted by counsel, hence admissible.
    • Damages were awarded to the victim’s heirs and appellant sentenced to reclusion perpetua.

Issues:

  • Whether the extrajudicial confession of the appellant was valid and admissible.
  • Whether the prosecution presented sufficient evidence to prove appellant’s guilt beyond reasonable doubt.
  • Whether the defense of alibi was valid and should negate the prosecution’s case.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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