Case Digest (G.R. No. 126955)
Facts:
People of the Philippines v. Romeo Tizon y Inking, G.R. No. 126955, October 28, 1999, the Supreme Court En Banc, Vitug, J., writing for the Court.The People of the Philippines (plaintiff-appellee) charged accused-appellant Romeo Tizon y Inking a.k.a. Romy Bondat/Bungal with rape with homicide in an Information alleging that on or about August 21, 1996 he forcibly dragged eight-year-old Jonabel Antolin into a warehouse in Binondo, Manila, repeatedly banged her head on the floor, had carnal knowledge of her, and inflicted fatal injuries. The Information was filed by the Assistant City Prosecutor and identified witnesses for the prosecution.
On September 10, 1996, the accused, with court‑appointed counsel, was arraigned and pleaded guilty. The trial court proceeded to receive evidence to determine the precise degree of culpability as required for a capital offense plea. The prosecution presented several witnesses: a teenage neighbor who placed the accused at the scene shortly before the victim’s death; the medico‑legal officer who testified as to sexual violation and cause of death; a forensic chemist who examined the accused’s clothing; police investigators who took the accused’s confession and arrested him; and family members and neighbors who placed the accused in the vicinity and described discovering the victim’s body. The defense called one barangay kagawad who testified that the accused had surrendered voluntarily through relatives; no other defense witnesses testified.
On October 30, 1996, after reception of evidence, the Regional Trial Court of Manila, Branch 41 (trial court) found the accused guilty as charged, imposed the penalty of death, and ordered payment of P200,000 to the victim’s heirs for actual and moral damages. Because a death sentence was imposed, the case came to the Supreme Court by automatic review.
In his brief to the Court, the accused challenged (1) the sufficiency of the prosecution’s evidence to establish rape (arguing the proper conviction should have been acts of lasciviousness and homicide) and (2) the award of P200,000 as unsupported by evidence. On review, the Supreme Court examined the arraignment record and found the only documentary proof was an or...(Pro-only)
Issues:
- Was the accused’s plea of guilty to a capital offense made voluntarily and with full comprehension in compliance with Rule 116, Sections 1 and 3 of the Rules of Court?
- In view of the alleged deficiencies in arraignment and plea proceedings, should the conviction and death sentence be upheld or annulled?
- Was the trial court’s award of P200,000 to the heirs of th...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)