Case Digest (G.R. No. L-19929)
Facts:
People of the Philippines v. Manuel Sta. Maria, et al., G.R. No. L-19919. October 30, 1965, the Supreme Court En Banc, Per Curiam. The plaintiff-appellee is the People of the Philippines; the defendants-appellants are Manuel Sta. Maria, Francisco Sta. Maria, Ignacio de Guzman, Juanito dela Cruz, Restituto dela Cruz, Alfonso Balinguit, and Ruperto Santos.On the night of December 15, 1959, Domingo Sanqui (the victim) was sleeping in his barn at Malibay, San Miguel, Bulacan, when a group of men—one of whom identified himself as a policeman—entered, restrained and abducted him. A ransom note demanding P30,000 (later reduced in reported conversation to P20,000) was found in the victim’s house; the note was prepared by Manuel Sta. Maria upon instruction of Ignacio de Guzman. The abductors transported the victim to the Tela Kawa mountains, where the victim was shot and thereafter hacked; his decapitated body was later recovered and identified, and autopsy showed multiple skull fractures and severe brain injury.
Investigations led to the arrest of several suspects. Juanito dela Cruz made an extrajudicial confession on December 23, 1959, which prompted further arrests; Ruperto Santos and Alfonso Balinguit made written confessions and guided authorities to the victim’s body. Manuel, Francisco and Ignacio likewise signed confessions before Justice of the Peace Lorenzo B. Tecson. Some accused initially pleaded not guilty at arraignment (February 9, 1960), but four—Juanito dela Cruz, Restituto dela Cruz, Alfonso Balinguit, and Ruperto Santos—later withdrew not-guilty pleas and pleaded guilty during trial; Restituto had earlier pleaded guilty before a justice of the peace. The Court of First Instance of Bulacan found all seven guilty of kidnapping with murder and sentenced each to death under Article 267 of the Revised Penal Code as amended (citing Republic Act No. 1084); it also ordered indemnity to the heirs. By operation of law the case was forwarded to the Supreme Court for review of the capital sentences.
The appeal raised factual and legal claims: involuntariness or lack of understanding of guilty pleas; insufficiency of ev...(Pro-only)
Issues:
- Were the pleas of guilty entered by Restituto dela Cruz, Juanito dela Cruz, Alfonso Balinguit and Ruperto Santos voluntary and made with understanding of their consequences?
- Was the evidence sufficient to establish beyond reasonable doubt the guilt of Manuel Sta. Maria, Francisco Sta. Maria and Ignacio de Guzman for kidnapping with murder?
- Were the confessions of Manuel Sta. Maria, Francisco Sta. Maria and Ignacio de Guzman voluntary and admissible?
- Was the imposition of the death penalty proper, and should the s...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)