G.R. No. L-38348 - People vs. Onavia

Ernesto Onavia, the accused, is an inmate at New Bilibid Prisons, Muntinlupa, Metro Manila, originally serving a sentence for Robbery in Band with Double Homicide and Multiple Rape.
Onavia was a member of the "Genuine Ilocano Gang" (GIG) while the victim, Federico Mansilungan, who was also a convicted prisoner, belonged to a rival faction known as the "Sigue-sigue Commando Gang."
The case arose from an incident within the prison compound on or about April 4, 1971, at approximately 3:00 P.M., when Mansilungan was fatally stabbed.

The Information charged Onavia with Murder, qualified by treachery and attended by evident premeditation and recidivism.
The victim sustained six stab wounds—three of which were fatal, affecting the upper lobe of the left lung, the liver, and the abdominal aorta, among other injuries.
Testimony of the Senior Medico-Legal Officer of the National Bureau of Investigation and prison investigators (including Buenaventura de la Cuesta and Francisco A. Cometa) established the timeline and specifics of the injuries and the sequence of events.
Onavia’s sworn statement (Exhibit "C") recorded in the evening of the incident admitted that he was the first to stab Mansilungan, and it detailed how he retrieved his "matalas" (a pointed weapon) and proceeded with the stabbing.
Additional evidence showed that Romeo Pasmala, a fellow inmate from the Happy Go Lucky Gang, also participated in the assault, although he died before being charged in court.

Upon arraignment, Onavia pleaded not guilty; however, on the scheduled day for the presentation of the defense's evidence, he moved through counsel to substitute his plea with a plea of guilty.
Despite the plea of guilty, the trial continued with Onavia taking the witness stand and testifying in his defense.
The trial court recorded his admissions, which included various details of the stabbing, such as his claim that the victim was armed with a “balila” and that the victim had struck him first.
On cross-examination, Onavia confirmed that he stabbed the victim "by surprise" and verified that his statement was given voluntarily.

The trial court convicted Onavia of Murder under Article 248 of the Revised Penal Code and imposed the death penalty, along with civil indemnity and damages.
The court found that the crime was qualified by evident premeditation and recidivism due to Onavia’s prior conviction for a serious offense.
Although treachery was initially considered, the trial court later reasoned that the circumstances did not fully meet the definition—since the victim was not completely caught off guard and had the opportunity to defend himself.

On appeal, the defense argued that the plea of guilty was improvidently accepted and that Onavia’s confession was not voluntary.
The reviewing court, after examining the evidence and the testimonies (including those corroborating the voluntary nature of the confession), upheld the trial court's factual findings.
Ultimately, although the aggravating circumstances of evident premeditation and quasi-recidivism (by reason of his previous conviction) supported a severe penalty, the death sentence was modified to reclusion perpetua in view of Onavia’s admission of guilt and apparent moral disposition to reform.

Was the plea of guilty, which the court accepted after evidence had been presented for the prosecution, proper and informed?
Did the trial court ensure that Onavia fully comprehended the nature and consequences of changing his plea from not guilty to guilty?

Was the accused’s sworn statement, which admitted to stabbing the victim and recounted the circumstances of the crime, given voluntarily?
How does the evidence, including cross-examination and corroborative testimony, establish the absence of coercion in obtaining the confession?

Did the evidence support the presence of evident premeditation, in light of the time gap between the gang leader’s instruction and the commission of the crime?
Was the element of treachery properly applied, considering whether the victim had any opportunity to defend himself?
Is the aggravating circumstance of quasi-recidivism justified by Onavia’s prior conviction for Robbery in Band with Double Homicide and Multiple Rape?

Given the mitigating factor of the accused’s admission of guilt and moral disposition, was the imposition of the maximum penalty (death) warranted?
Should the penalty be modified to reflect both the aggravating and mitigating circumstances presented during trial?