Case Summary (G.R. No. L-20953)
Initial Proceedings
Felipe Villas y Tanti was charged with robbery with homicide and rape in the Court of First Instance of Manila. Upon his arraignment, Villas y Tanti initially pleaded not guilty. However, after his counsel indicated a lack of understanding of the charges, the trial court permitted him to withdraw his plea. He was subsequently arraigned again, during which he understood the allegations as translated into his native "waray-waray" dialect and ultimately pleaded guilty.
Trial and Evidence Presented
Despite the guilty plea, the trial court ordered the prosecution to present evidence to substantiate the aggravating and mitigating factors of the case. Key testimonies were provided by Detective Alfredo Lazarte regarding the defendant's confession, as well as witnesses such as Teresita Zavalla, Dr. Mariano B. de Lara, and Daisy Orly de Gagui. The defendant waived his right to present evidence during these proceedings.
Judgment and Sentencing
On February 1, 1963, the trial court found Villas y Tanti guilty beyond a reasonable doubt of robbery with homicide and rape. The court identified aggravating circumstances: grave abuse of confidence and nocturnity, which were countered by the mitigating factor of a voluntary plea of guilty. Consequently, the defendant was sentenced to death by electrocution and ordered to pay indemnity to the heirs of the victim, Catalina Colman.
Circumstances of the Crime
The events leading to the crime occurred on the evening of October 3, 1962, when the victim and a companion left the flower shop for a hospital visit. After closing the shop, Villas y Tanti reentered the premises using a key he had previously accessed. He concealed himself in Colman’s room, intending to steal from her once she fell asleep. Upon her return, he attacked her with a hammer, causing fatal injuries, sexually assaulted her, and subsequently stole cash and jewelry.
Autopsy Findings
An autopsy revealed Catalina Colman's cause of death as extensive cranial and chest injuries resulting from repeated blunt force trauma. These findings corroborated the crime's violent nature and underscored the gravity of the defendant's actions, which included both homicide and rape.
Voluntary Confession and Legal Defenses
Initially denying involvement, Villas y Tanti later confessed to the crime. His attorney de oficio contested the trial court's findings related to the aggravating circumstances and the severe pena
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Background of the Case
- The case concerns Felipe Villas y Tanti, charged with robbery with homicide and rape.
- Upon arraignment, he initially pleaded not guilty. However, his counsel later indicated that he did not fully understand the information read to him.
- The trial court permitted him to withdraw his plea and ordered a new arraignment in the "waray-waray" dialect, appropriate for his background from Leyte.
- After being rearraigned, Villas y Tanti pleaded guilty.
Trial Proceedings
- The trial court proceeded to gather evidence despite the guilty plea, particularly regarding aggravating and mitigating circumstances.
- The prosecution presented various witnesses, including Detective Alfredo Lazarte, Teresita Zavalla, Dr. Mariano B. de Lara, and Daisy Orly de Gagui.
- The defendant waived his right to present evidence in his defense.
Judgment of the Trial Court
- On February 1, 1963, the trial court convicted Villas y Tanti.
- He was found guilty beyond a reasonable doubt of robbery with homicide, complexed by rape, in violation of relevant articles of the Revised Penal Code.
- The court recognized aggravating circumstances of grave abuse of confidence and nocturnity, countered by the mitigating circumstance of a voluntary plea of guilty.
- The defendant wa