Case Summary (G.R. No. 71980)
Details of the Crimes
Mercedes Dulay was attacked and killed by the defendants who, with intent to rape and kill, took turns assaulting her and subsequently caused her death through multiple stab wounds and other severe injuries. The heinousness of the crime extended to the subsequent desecration of the victim's body, including the insertion of a branch into her vaginal canal and the stealing of items, such as a gold ring and a wristwatch. The defendants acted in conspiracy and demonstrated premeditation, as evidenced by their prior planning and coordination of the attack.
Proceedings and Initial Confessions
Leonardo Flores initially pleaded guilty during the arraignment; however, the court chose to record a plea of not guilty to allow him the opportunity to engage counsel. Eventually, he reaffirmed his guilty plea and later testified extensively against his co-defendants, outlining their actions before and during the crime—including their collective plan to assault Mercedes and the details of the subsequent rape and murder.
Testimonies and Evidence
Flores testified that he and the other defendants consumed alcohol and drugs before agreeing to commit the crime, demonstrating a degree of planning and deliberation. After the murder, they attempted to conceal their act by disposing of the victim’s body in a nearby canal and stealing her possessions. Forensic evidence, including the autopsy results, confirmed the victim sustained numerous fatal injuries and was raped, further establishing the claims made during the trial about the brutality of the crimes.
Verdict and Sentencing
The Regional Trial Court found all four defendants guilty of the special complex crime of multiple rape with homicide. Given the aggravating circumstances and the confirmed conspiracy, the court initially imposed a death penalty for each defendant. However, as the case progressed into the 1990s and in light of the newly enacted 1987 Philippine Constitution, which abolished the death penalty, the punishment was reconsidered and converted to reclusion perpetua instead.
Appeals and Legal Arguments
The defendants Cruz, Parinas, and Sarsoza appealed the court's decision, arguing several deficiencies in the evidence, particularly challenging the credibility of Flores' testimony and the court's reliance on his confession. The court acknowledged the concerns regarding confessions but defended the reliability of Flores' judicial confession based on his demeanor and the consistency of details provided when recounting the events of the crime.
Conclusion
Ultimately, the appellate court
...continue readingCase Syllabus (G.R. No. 71980)
Case Background
- The case involves the brutal rape and murder of Mercedes M. Dulay, a registered nurse, on the night of September 21, 1984.
- Dulay's body was discovered the following morning in an irrigation canal with multiple stab and hack wounds, and a branch of ipil-ipil wood inserted into her vagina.
- The accused are Leonardo Flores, Alex King Cruz, Servillano Parinas, and Ernesto Sarsoza, who were later charged with rape with homicide and robbery.
Incident Description
- The police received a report regarding Dulay's death and found her body shortly after.
- Witnesses, including the victim's family, testified about her character and her usual route home.
- Flores was arrested a few hours after the crime and confessed to being involved with his companions, leading to their arrest.
Charges and Arraignment
- The defendants were charged with multiple counts of rape with homicide and robbery in the Regional Trial Court.
- Upon arraignment, Cruz, Parinas, and Sarsoza pleaded not guilty, while Flores initially pleaded guilty but later changed to not guilty before reiterating his guilty plea.
Testimonies and Evidence
- Flores testified that he and the other accused conspired to rape and kill Dulay after consuming alcohol and drugs.
- They ambushed Dulay, physically assaulted her, and repeatedly raped her despite her pleas for mercy.
- Postmortem findings indicated numerous injuries on