Case Summary (G.R. No. 67662)
Background of the Appellant
Marcos Manalang, a cousin of Maximino Lorenzo, became part of the Lorenzo household after being given a job by Maximino in 1978. The Lorenzo family supported him through college, but his romantic involvement with Maggie Chavez led him to neglect his studies and become financially dependent. Feeling pressured and desperate, he believed that the Lorenzo family obstructed his relationship with Maggie.
Description of the Crimes
On January 3, 1984, while the Lorenzo couple was at work, Manalang executed a plan to eliminate all family members he saw as impediments to his love for Maggie. He first attacked Felisa Capalungan with a kitchen knife, subsequently killing her grandson Carlomax and then Lawrence. He also murdered their housemaid, Zenaida, using a hammer and a butcher's knife.
Details of the Aftermath
After the murders, the appellant attempted to cover up his actions by disposing of evidence and packing his belongings. He subsequently robbed the Lorenzo house of cash and valuables. Post-crimes, Manalang sought medical treatment for his self-inflicted wounds, and as he evaded authorities, he wrote letters confessing to the killings, later surrendering to law enforcement.
Charges and Initial Proceedings
Manalang was charged with Robbery with Multiple Homicide in the Regional Trial Court, where he confessed to the murders during his arraignment. The trial court found that the intent behind the actions was primarily to kill rather than to rob, leading to separate charges of Murder and Theft instead of the initially mentioned complex crime.
Verdict and Sentencing
The trial court sentenced Manalang to death for each of the murders, along with a distinct sentence for Theft due to the taking of valuables from the Lorenzo household. However, upon review by the higher tribunal, the death sentence was commuted to reclusion perpetua in light of the 1987 constitutional prohibition against capital punishment. The court affirmed the total convictions of four murders and one count of theft, adjusting damages to reflect a new standard compensation for the heirs of the victims.
Legal Principles Involved
The case underscores the differentiation between murder and robbery, particularly concerning the original intent of the accused. The court highlighted that if the intent to kill exists independently of theft, the resultant acts may const
...continue readingCase Syllabus (G.R. No. 67662)
Background of the Case
- The case revolves around Marcos Manalang, whose obsession with Maggie Chaves culminated in the horrific murders of four people: Felisa Capalungan Vda. de Lorenzo, Carlomax Lorenzo, Lawrence Lorenzo, and Zenaida Nicobeza.
- The Lorenzo family, consisting of Engineer Maximino Lorenzo, Edith Bolivar-Lorenzo, and their two children, resided in Lagro Subdivision, Novaliches, Quezon City, where they also provided shelter and support to Marcos.
Relationship Dynamics
- Marcos became close to the Lorenzo family after being hired by Maximino as a timekeeper in 1978.
- He was treated as a son, with the family supporting his education, which he ultimately neglected due to his relationship with Maggie.
- This neglect led to a sense of desperation in Marcos as he feared losing both his education and his relationship.
The Crime
- On January 3, 1984, Marcos decided to murder the Lorenzo family, whom he perceived as obstacles to his relationship with Maggie.
- He utilized a kitchen knife, hammer, and butcher knife to execute his plan after the family members had left the house.
- The murders were brutal and involved stabbing Felisa while she was sewing, attacking the sleeping children, and ultimately killing Zenaida upon her return.
Aftermath of the Murders
- Following the murders, Marcos attempted to cover up the crime by hiding the bodies and cleaning the scene.