Case Summary (G.R. No. L-38859)
Factual Background
Erlinda Manzano was reported missing by her parents after she did not return home from her job as a waitress. Two days later, her body was discovered in almost a naked state, with evidence indicating that she had been sexually assaulted and strangled. Medical examinations confirmed the cause of death as ligature strangulation, and there were signs of sexual intercourse involving force.
Investigation and Charges
The police undertook a manhunt for the suspects, resulting in the arrest of several individuals, including the accused. In their confessions, the accused admitted to partaking in the rape of Erlinda, detailing their respective roles in the crime. A formal complaint, signed by Erlinda's father and the Assistant Fiscal, led to charges of rape with homicide against the accused.
Trial Proceedings
During the trial, the accused presented alibis to contest the prosecution's case, claiming they were engaged in unrelated activities at the time of the incident. The trial court, however, found these alibis unconvincing, especially given the testimonies of state witness Rodolfo Bagtasos, who provided a detailed account of the events leading to Erlinda's death.
Verdict and Sentencing
The trial court convicted Vizcarra, Salamatin, Delos Reyes, and Fernando, sentencing them to death based on Article 335 of the Revised Penal Code, considering the occurrence of multiple aggravating circumstances such as the nighttime setting and the use of superior strength in committing the crime.
Appeal and Judicial Review
The case was subject to mandatory review, and during the appellate process, the appellants challenged not only the evidence presented against them but also the validity of their confessions, alleging coercion. Ultimately, the court upheld the trial court’s findings, stating that the overwhelming evidence supported their convictions.
Legal Principles and Findings
The court reiterated the legal principle that alibi is generally a weak defense and emphasized that the confessions made by the appellants were truthful and consensual. The court distinguished between the roles of each accused i
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Case Overview
- The case involves a review of the judgment rendered by the Court of First Instance of Rizal, which imposed the death penalty on the accused for the crime of rape with homicide.
- The accused are Danilo Vizcarra, Leobino Salamatin, Jose Delos Reyes, and Liberato Fernando.
- The victim, Erlinda Manzano, was a 14-year-old waitress whose body was discovered two days after her disappearance on June 25, 1969.
Incident Details
- Erlinda Manzano went missing on the night of June 25, 1969, and her parents reported her disappearance to the police after failing to find her.
- Her body was discovered in a vacant lot with signs of strangulation and sexual assault.
- Medical examinations revealed injuries consistent with sexual violence and asphyxia due to ligature strangulation.
Evidence and Investigation
- A massive manhunt was launched, leading to the arrest of several suspects, including the appellants.
- The suspects provided written statements confessing their involvement in the crime, identifying each other as participants in the acts of rape and the subsequent murder of Erlinda.
- Rodolfo Bagtasos, a state witness, testified about the events leading up to the crime, detailing the actions of the a