Case Summary (G.R. No. L-28255)
Facts of the Case
On June 9, 1967, Clarita, along with her siblings, was lured to the second floor of Magtira's home under suspicious circumstances. After her mother, Juanita Sarmiento, failed to locate Clarita by 4 p.m., she initiated a search and later found Clarita’s lifeless body covered by a mat in Magtira’s house. A postmortem examination conducted by Dr. Diosdado Asuncion revealed evidence of sexual assault and strangulation, indicating that Clarita had been raped before her death.
Confession and Evidence
Following the discovery of the body, Magtira was arrested by the police and later confessed to the crime, detailing how he had both raped and killed the victim. His confession was documented in an extrajudicial statement, which formed part of the prosecution's evidence. The trial court also admitted several circumstantial pieces of evidence, including blood-stained clothing associated with Magtira.
Allegations of Coercion
Magtira attempted to contest the admissibility of his confession by claiming it was obtained under coercive circumstances. He argued that he had been assaulted by police officers during the investigation, which led to his involuntary confession. However, the court established that the confession was voluntary, particularly as it was made in front of a municipal judge who clarified Magtira's rights.
Trial Court’s Findings
The trial court found Magtira guilty beyond reasonable doubt, based on both his confession and the circumstantial evidence linking him to the crime. Among these were the blood-stained trousers he allegedly attempted to have laundered shortly after the incident, and the damning testimonies from witnesses, including Clarita’s brother Valeriano who observed her going up to the house at Magtira's behest.
Legal Conclusions
The court emphasized the gravity of crimes involving minors and noted that the absence of doubt regarding Magtira's guilt warranted the imposition of the death penalty. Moreover, the court cited precedents underscoring the importanc
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Case Overview
- The case revolves around the heinous crimes of rape and homicide committed against ten-year-old Clarita S. Constantino.
- Accused-appellant Martin Magtira y Dela Cruz, aged 33 at the time of the crime, was charged and subsequently convicted, receiving the death penalty.
- The trial court also ordered him to indemnify the victim's heirs in the amount of P6,000.00, with no subsidiary imprisonment for insolvency, and to pay the costs of the trial.
Factual Background
- The crime occurred on June 9, 1967, in barrio Baluganon, Masinloc, Zambales, where the victim lived with her mother, Juanita Sarmiento, and her siblings.
- Martin Magtira, known locally as 'Pocol' due to a physical disability, lived approximately 30 meters from the Constantino household.
- At around 2:00 PM, Clarita and her siblings were playing outside when Magtira called Clarita to his house, sending her siblings away.
Discovery of the Crime
- At around 4:00 PM, Juanita Sarmiento noticed Clarita was missing and began searching for her.
- Valeriano, Clarita's brother, eventually recalled that Clarita had gone to Magtira's house.
- Upon searching Magtira's home, Juanita found Clarita's lifeless body on the bamboo floor, covered by a mat, with signs of sexual assaul