G.R. No. L-49188 - Philippine Airlines, Inc. vs. Court of Appeals

Felipe Villas y Tanti, aged 27 and single, was employed for almost four years as a “house boy” or helper at the Afable Flower Shop owned by the now-deceased Catalina Colman, a 47-year-old spinster.
His duties included cleaning the premises, running errands, and having authorized access to both the shop and the victim’s private room.
The defendant resided in the premises together with other helpers and relatives, indicating a trusted relationship with the victim.

Initially charged with robbery with homicide and rape, the defendant pleaded not guilty at arraignment.
Due to language difficulties—the charges were read in a language not fully understood by the defendant—the de officio counsel requested and was granted permission to withdraw the not-guilty plea.
After clarifying the charge by translating it into the Waray-Waray dialect (in view of his Leyte origins), the defendant was rearraigned and subsequently pleaded guilty.

During the hearing held on November 12, 1962, the prosecution introduced several pieces of evidence and witness testimonies:

Detective Alfredo Lazarte presented the defendant’s extrajudicial confession (Exhibit A) and described a reenactment of the crime.
Teresita Zavalla, a niece and helper at the Afable Flower Shop, testified regarding her relation to both the victim and the scene.
Dr. Mariano B. de Lara, medico-legal officer of the Manila Police Department, provided an autopsy report establishing the cause and nature of the injuries suffered by the victim.
Daisy Orly de Gagui, the victim’s sister, also contributed testimony.

The defendant, through his counsel, expressly waived his right to present evidence in his defense.

At around 8:00 p.m., the victim, accompanied by Teresita, left the premises for a visit to Lourdes Hospital.
The defendant closed the flower shop at 9:00 p.m. but later reentered at 10:00 p.m. using a key left near the rear door.
He entered the private room of Catalina, leaving the door unlocked, and hid under the bed with the intention of stealing a dresser key once the victim was asleep.

At approximately 11:00 p.m. Catalina returned to her room and began preparing for sleep, believing she was secure in her privacy.
The defendant emerged from under the bed, armed with a hammer retrieved from near a wooden trunk, expecting the victim to be asleep.
Upon discovering that the victim was alert and awake, he struck her multiple times—initially on the face and then with additional blows on other parts of her body—thereby causing severe head and facial injuries.
While the victim lay prostrate, the defendant removed her underwear and proceeded to rape her.
Following the assault, he stole money (amounting to P476.80) from her night table by using a key later taken from her bag, and also appropriated jewelry, a piggy bank from her bed, and a ring from her left finger.
The stolen jewelry was wrapped in her blue dress and hidden in the storeroom, while the cash was concealed underground just outside the premises.
The defendant subsequently removed his blood-stained clothes, placing them into a can filled with water.

At about 6:00 a.m., the defendant returned to the flower shop and falsely informed his co-worker Ernesto that robbers had broken in.
Ernesto then awakened Teresita, who, upon discovering the lifeless body of Catalina, called the police.
An autopsy conducted by Dr. de Lara confirmed the timeline of injuries and established the cause of death as extensive depressed fragmentary fractures in the left side of the cranium, compounded by rib fractures and a massive left epidural hematoma.

Initially, when interrogated, the defendant denied any involvement in the crime.
On October 11, 1962, he confessed to the commission of the crime, with the confession being authenticated and undisputed in terms of its voluntariness.
The trial court, notwithstanding the defendant’s guilty plea, ordered the presentation of additional evidence regarding the alleged aggravating circumstances (nocturnity and grave abuse of confidence) and any possible mitigating circumstances.
On February 1, 1963, the trial court rendered judgment finding the defendant guilty with moral and legal certainty and imposed the penalty of death by electrocution, alongside accessory penalties, including indemnification for the victim’s heirs and the payment of court costs.

The trial court erred in finding the aggravating circumstances of nocturnity and grave abuse of confidence.
As a result, the imposition of the death penalty by electrocution, instead of reclusion perpetua, was improper.

However, the evidence in the record—including the confession, witness testimonies, and autopsy findings—supported the trial court’s finding that the circumstances of the crime necessitated the imposition of the capital penalty.

Whether the trial court correctly found and applied the aggravating circumstances of nocturnity and grave abuse of confidence in the commission of the crime.
Whether the imposition of the death penalty by electrocution, rather than reclusion perpetua, was justified in light of the evidence and the established aggravating circumstances.
Whether the evidence presented, including the defendant’s confession and the autopsy report, established beyond reasonable doubt the guilt of the defendant for the crimes charged.