G.R. No. 32723 - People vs. Tria

On November 25, 1995, 18-year-old Lolita delas Alas left home at 6:00 AM for school in Nasugbu, Batangas; at 8:00 PM her naked, lifeless body was found in a sugar-cane field in Sitio Ilaya, Barangay Bunducan, strangled with a T-shirt and showing signs of forcible rape.
Witnesses saw accused Roberto Samontañez y Dela Vega near the scene: at 5:30 PM he passed Melecio Mendoza’s house heading east toward the plantation; at 6:30 PM he emerged from the same field, shirtless and pale; at 7:00 PM he returned westward along the same path.

Police recovered the victim’s personal effects from Roberto’s workplace in Mendez, Cavite, after he admitted in custody that her belongings were in his bag.
Forensic examination by Dr. Estela Hizon revealed contusions consistent with fist blows, hymenal lacerations, and asphyxia by strangulation. Photographs, scene sketches, and barangay clearance were also seized.

January 11, 1996: Information filed for rape with homicide (Art. 335 RPC, as amended); accused initially pleaded “not guilty.”
March 14, 1996: Through counsel de oficio, he sought to change his plea to “guilty”; court re-arraigned him in Tagalog, conducted a cursory inquiry, and required the prosecution to present proof per Rule 116, Sec. 3.
November 1997–January 1998: Accused reiterated his guilty plea in hearings, later claiming pressure by a policeman; court elicited confirmations but did not explore coercion.
May 15, 1998: RTC Branch 14, Nasugbu convicted him of rape with homicide, imposed death penalty, and awarded P190,000 compensatory and moral damages; decision subjected to automatic SC review.

Whether the plea of guilty to a capital offense was made voluntarily and with full comprehension as mandated by Rule 116, Sec. 3.
Whether the trial court conducted an adequate “searching inquiry” into coercion, understanding of elements, mandatory penalty, and civil liabilities.

Whether the accused’s custodial statements and the recovery of the victim’s belongings at his workplace were admissible, given the absence of Miranda-type warnings and counsel.
Whether such evidence constitutes the “fruit of the poisonous tree” and must be excluded.

Whether the testimonies of lay witnesses and forensic findings alone could sustain conviction beyond reasonable doubt, apart from the plea and tainted evidence.