Title
People vs. Onavia
Case
G.R. No. L-38348
Decision Date
Jan 27, 1983
Inmate Ernesto Onavia, serving time for prior crimes, fatally stabbed rival gang member Federico Mansilungan in prison. Convicted of murder with evident premeditation, his death penalty was reduced to reclusion perpetua by the Supreme Court.

Case Summary (G.R. No. L-38348)

Detailed Allegations and Charges

Onovia was charged with the murder of Mansilungan, qualified by treachery, evident premeditation, and recidivism. The specifics of the Information indicated that on April 4, 1971, during his confinement, Onavia, armed with an improvised weapon, deliberately attacked and stabbed an unarmed Mansilungan, resulting in the victim's death due to multiple stab wounds. It was noted that Onavia had a prior conviction for Robbery in Band with Double Homicide and Multiple Rape.

Proceedings and Plea

Initially, Onavia pleaded not guilty. However, after the prosecution rested its case, he moved to change his plea to guilty, which the trial court accepted. Onavia subsequently testified in his defense, claiming that the victim attacked him first, which prompted his response.

Judgment and Sentencing

Following the proceedings, the trial court rendered a judgment convicting Onavia of murder, imposing the death penalty. The court determined the presence of treachery and evident premeditation but noted the aggravating circumstance of recidivism based on Onavia's prior conviction.

Evidence Presented

The prosecution's evidence included testimonies from prison guards and investigators, alongside Onavia's own confession and statements made following the incident. The forensic examination revealed that Mansilungan sustained fatal injuries from multiple stab wounds. Onavia's testimony during the trial suggested a degree of premeditation based on instructions from his gang leader prior to the incident.

Criminal Liability and Legal Standards

The defense contested the validity of the guilty plea and the voluntary nature of Onavia's statements. Nevertheless, the trial court maintained that the full measure of evidence supported the conviction beyond reasonable doubt. The court further clarified that accepting a guilty plea does not preclude the necessity for evidence to establish the degree of culpability.

Review of Aggravating Circumstances

While the trial court identified treachery as a factor, the reviewing body disagreed, stating that the victim had a chance to defend himself, and thus treachery could not apply. Conversely, evident premeditation was confirmed due to Onavia’s premedita

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