G.R. No. 130189 - People vs. Muleta

Case Summary (G.R. No. 130189)

Case Background and Charges

Domingo R. Muleta was charged with the complex crime of rape with homicide for allegedly raping and killing his niece, Charito Delgado, on April 30, 1993, in Malolos, Bulacan. The Information detailed that Muleta took advantage of superior strength, used force and intimidation while the victim was unconscious, and stabbed her causing instantaneous death. Muleta pleaded not guilty.

Facts as Presented by the Prosecution

Charito Delgado had relocated several times and was last seen alive in Tondo, Manila. Her body was found naked, tied to a post with bra and pants, bearing multiple stab wounds. The NBI took over the investigation and summoned Muleta for custodial investigation where he allegedly confessed to the crimes. Witnesses testified regarding Muleta’s hysterical behavior at the victim’s wake, including uttering remorseful words and drinking chlorine (“chlorox”) before being hospitalized.

Version of the Defense

Muleta denied committing the crime, asserting he was forcibly picked up and tortured by the NBI to extract a false confession without the assistance of counsel. He claimed his whereabouts at the time of the crime were at home with his wife in Tondo, Manila, supported by his wife’s testimony. He also recounted efforts to report the victim missing to the police authorities, claimed the NBI tortured him during interrogation, and insisted that his confession was coerced.

Findings and Rationale of the Regional Trial Court (RTC)

The RTC convicted Muleta based solely on circumstantial evidence supported by the extrajudicial confession. The court found that:

Muleta was familiar with the crime site.
He left work late evening on April 29 and only returned home the following morning.
His behavior and utterances at the wake were indicative of guilt and remorse.
He admitted to the confession that contained intimate details of the crime.
The extrajudicial confession was valid and voluntary, assisted by counsel, and unrebutted by medical or eyewitness testimony of torture.
The defense’s alibi lacked credible support, and no motive to fabricate testimony by prosecution witnesses was shown.

Issues on Appeal

Validity and admissibility of the extrajudicial confession.
Sufficiency of the prosecution’s evidence to prove guilt beyond reasonable doubt.
The effectiveness of the alibi defense.

Supreme Court’s Analysis on the Extrajudicial Confession

The Court ruled that Muleta’s extrajudicial confession was inadmissible due to violations of constitutional rights under the 1987 Constitution, particularly:

Right to be informed: The manner in which Muleta was informed of his rights was superficial, perfunctory, and failed to ensure his understanding, which falls short of constitutional standards of effective communication and comprehension.
Right to counsel: Although the prosecution claimed that attorney Daquiz assisted Muleta, testimonies revealed that the confession-taking began on September 19, 1993, without counsel present; counsel arrived only on September 20, 1993. The confession was subscribed and sworn on September 19, 1993, thus completed without counsel; this violated the constitutional right to have counsel present during custodial investigation and waiver of rights. The prosecution’s failure to produce claimant counsel further undermined the confession’s validity.
Right to waive rights in writing and presence of counsel: The purported waiver incorporated vague language without demonstrating Muleta’s understanding and voluntary relinquishment of rights. The so-called waiver was insufficient and did not conform to the constitutional requirement for a knowing, voluntary, and express waiver, especially absent counsel’s proper participation.

The exclusionary rule mandates disregarding any confession obtained in violation of constitutional safeguards.

Sufficiency of the Remaining Evidence

With the confession excluded, the prosecution’s remaining evidence consisted of circumstantial evidence which:

Did not prove that Muleta was at the scene (prosecution’s witness relied on hearsay regarding work hours and whereabouts).
Was contradicted by credible testimony of Muleta and his wife who testified to his presence at home.
Included ambiguous remarks at the wake which did not conclusively demonstrate guilt but only suspicion.
Lacked an unbroken chain of circumstances that would exclude all other reasonable hypotheses but Muleta’s guilt, as required in circumstantial evidence cases.

The Court reaffirmed the principle that conviction must rest on the prosecution’s strength, not the defense’s weakness, and that suspicion is not tantamount to proof beyond reasonable doubt.

On Alibi as a Defense

While recognizing that alibi as a defense is inherently weak, the Court emphasized that the prosecution bears the burden of proof and must rely on the strength of its own evidence. Since the prosecution failed to exclude the possibility of Muleta’s alibi, the defense was entitled to take advantage of the reasonable doubt.

Constitutional Guarantees and Presumption of Innocence

The Court underscored that the accused should be presumed innocent unless proven guilty beyond reasonable doubt by credible and admissible evidence. Since the confession was excluded and circumstantial evidence was inadequate, the constitutional presumption of innocence prevailed and required acquittal.

Final Disposition

The Supreme Court granted the appeal, reversed and set aside the RTC’s judgment, and acquitted Domingo R. Muleta due to insufficiency of evidence. The Court directed the Bureau of Corrections to immediately release him unless lawful

Case Syllabus (G.R. No. 130189)

Case Background and Charge

Domingo R. Muleta was charged with the complex crime of rape with homicide, alleged to have occurred on April 30, 1993, at a house in Malolos, Bulacan.
The Information detailed that the accused willfully and unlawfully had carnal knowledge of Charito M. Delgado without her consent, using force and intimidation while she was unconscious, and subsequently stabbed her causing her instantaneous death.
Muleta pleaded not guilty upon arraignment.
The Regional Trial Court of Malolos found him guilty beyond reasonable doubt and sentenced him to reclusion perpetua, ordering damages for the victim’s heirs.
Muleta filed an appeal to the Supreme Court challenging the decision.

Prosecution’s Version of the Facts

Charito Delgado, aged 19, had moved to Manila for work and was last seen alive after returning to pick up her belongings in Tondo, Manila.
Her naked body was found on April 30, 1993, tied to a post in Mojon, Malolos, Bulacan, bearing multiple stab wounds.
Initial police investigation was later taken over by the National Bureau of Investigation (NBI), assigned agent Ely Tolentino.
Muleta is Charito’s maternal uncle and was working at Loadstar Shipping Lines in Tondo around the time of the crime.
On September 19, 1993, the NBI requested Muleta to accompany them for investigation; he complied.
During custodial investigation on that date, Muleta, assisted by counsel Atty. Deborah Daquiz, allegedly admitted to raping and killing Charito.
Witness Danilo Delgado testified about Muleta’s behavior at Charito’s wake—hysterical, remorseful, drinking chlorox and later hospitalized.

Defense Version of the Facts

Muleta denied committing the crime, asserting he was unlawfully taken by the NBI and coerced into confessing.
He claimed he was home in Tondo on April 30, 1993, and had actively sought help upon learning Charito was missing.
Stated he was working as a welder on contractual basis and was looking for other employment.
Alleged he was tortured by the NBI agents during investigation—boxed, kicked, blindfolded, water poured on nose, forced to sign document without reading or lawyer assistance.
Witness testimony including his wife asserted that Muleta stayed at home on the night in question.
Argued that his statements at the wake were expressions of grief, not admissions of guilt.

Findings and Judgment of the Trial Court

The trial court convicted Muleta based on circumstantial evidence and extrajudicial confession.
The conviction was supported by findings that the accused was familiar with the crime scene, left work late on the crime night, behaved hysterically during the wake, and admitted the crime in his sworn statement.
Admitted the extrajudicial confession with counsel assistance as voluntary and truthful.
Dismissed defense's claims of torture, lack of counsel, and alibi for lack of credible proof.
Held that the confession alone sufficed for conviction, and defense denial was bare assertion without credible evidence.

Assignment of Error and Issues on Appeal

Appellant raised the sole assignment that the trial court erred in giving weight to prosecution evidence and disregarded his defense of alibi.
Issues re