People vs. Mariano

A plea of guilty to a capital offense is valid where the trial court has sufficiently explained the nature of the charge and the consequences of the plea in language the accused can understand, and the conviction is independently supported by an unassailed extrajudicial confession corroborated by proof of the corpus delicti.

Mario Mariano y Alejandro, a resident of Tondo, Manila, who had completed Grade 6 at Princess Urduja School, was charged with the rape and killing of Luningning Mapola, the six-year-old adopted child of Juanita Mapola. The accused was born on May 29, 1956, making him twenty years old at the time of the offense, and was married on March 11, 1975. The case was subject to automatic review by the Supreme Court pursuant to the rules governing capital cases, the trial court having imposed the death penalty. The applicability of Presidential Decree No. 603 (Child and Youth Welfare Code) was also at issue, as the accused's age and marital status were relevant to the determination of whether he qualified as a youthful offender.

On November 11, 1976, in Tondo, Manila, six-year-old Luningning Mapola, the adopted child of Juanita Mapola, went missing. Juanita searched for the child and, through information from a small boy, found Luningning the following day at approximately three o'clock in the afternoon inside an uninhabited house on Fernandez Street. The child was already dead, her dress rolled up to her abdomen, without underwear, her eyes swollen, with blood having oozed from her left eye.

Earlier that same afternoon, at about two o'clock, a thirteen-year-old student named Rebecca Molina was walking at the corner of Fernandez and Laong Nasa Streets when the accused, Mario Mariano, whistled at her, causing her to run away. At approximately three o'clock that afternoon, a witness named Cesar Villanueva saw the accused walking unsteadily; when asked why, the accused answered that he had taken something, though he did not specify what. The accused later stated, upon questioning by the trial court, that the crime occurred between four and five o'clock in the afternoon inside a room of an uninhabited house on Laong-Nasa Street, where he had gone to fly his kite.

Upon arraignment on November 19, 1976, after the information was translated into Tagalog, the accused, assisted by counsel de oficio, entered a plea of guilty to the charge of rape with homicide, notwithstanding the trial judge's warning that the imposable penalty was death. The trial court, considering the gravity of the offense, set the case for hearing on November 25, 1976 to determine the nature of the crime and the precise culpability of the accused. On that date, the accused, now assisted by counsel de parte Atty. Narciso Santiago, reiterated his plea of guilty after the court again inquired whether he had maturely reflected on the consequences. The prosecution presented its witnesses, including Juanita Mapola, Rebecca Molina, Patrolman Santiago Vargas, and medico-legal officer Dr. Luis Larion. Patrolman Vargas testified that the accused gave a written confession voluntarily and re-enacted the commission of the crime. Dr. Larion declared on his autopsy of the victim.

The accused testified that he was born on May 29, 1956, and that he did not intend to kill the victim. He stated that the child died by accident when her head hit the pavement while she was struggling, and that he was prompted to rape her because he was not in his right senses, being an addict. On December 13, 1976, the trial court, at its own instance, reopened the case to receive additional evidence on whether the accused was legally married, this fact being material to the application of Presidential Decree No. 603. After several resetting of dates, on January 25, 1977, the prosecution presented the marriage contract showing the accused had married on March 11, 1975. The defense presented Dr. Angelo Singian, who testified that the death of the victim was due to laceration of the vagina caused by a stiffened male organ or the insertion of a hard blunt object out of proportion to the size of the vagina, and that the traumatic head injury was only contributory. The trial court concluded from the evidence that the accused committed the offense charged.

• Improvident Plea of Guilty: Petitioner argued that the trial court erred in improvidently accepting the plea of guilty without inquiring into the causes which brought about the same, or whether the accused fully understood the serious charge and the necessary implications of his plea to a capital offense, and in not taking the proper precautions directed in Supreme Court decisions and dictated by prudence under the circumstances, and thereafter convicting the accused to suffer the penalty of death.
• Lack of Intent to Kill: Petitioner testified that he did not intend to kill the victim, asserting that her death was accidental, occurring when her head hit the pavement while she was struggling.
• Drug Addiction: Petitioner claimed he was prompted to rape the victim because he was not in his right senses, being an addict.

• Validity of Plea of Guilty: Whether the trial court improvidently accepted the accused's plea of guilty to a capital offense without sufficient inquiry into whether the accused fully understood the charge and the consequences of his plea.
• Sufficiency of Evidence Independent of Plea: Whether there is sufficient evidence independent of the plea of guilty to sustain the conviction beyond reasonable doubt.
• Drug Addiction as Defense: Whether the accused's claim of drug addiction constitutes a valid defense to the crime charged.

• Validity of Plea of Guilty: No. The plea was providently accepted, the trial court having thoroughly explained the nature of the charge and the consequences of the plea in simple language the accused could understand, with the accused reiterating his plea when assisted by counsel of choice.
• Sufficiency of Evidence Independent of Plea: Yes. The accused's extrajudicial confession, the regularity of which was never assailed, together with his re-enactment of the crime, was fully corroborated by proof of the corpus delicti established through medical evidence from both prosecution and defense witnesses.
• Drug Addiction as Defense: No. Drug addiction is punishable by law, and nobody should profit therefrom; the accused's coherent confession and ability to re-enact the crime demonstrated he was not so impaired as to negate criminal responsibility.

• Validity of Plea of Guilty: The trial court took pains in explaining to the accused the precise nature of the crime charged and the effect of his plea of guilty. The dialogues between the accused and the court during arraignment and at the November 25, 1976 hearing show that the court used simple words easily understood by the accused, who had finished Grade 6. The information was read to him in Tagalog. Despite the court's efforts, the accused, assisted by counsel of choice Atty. Narciso Santiago, reiterated his plea. When represented by counsel of choice, the accused could have withdrawn his initial plea entered with counsel de oficio but did not. The contention that the accused's fate was sealed on November 25, 1976 was therefore without merit.
• Sufficiency of Evidence Independent of Plea: Independent of the plea of guilty, the accused executed an extrajudicial confession the regularity of which was never assailed. The confession showed he gave coherent answers to the questions propounded. He also re-enacted the commission of the crime, which he could not have done if he was not in his right senses. The testimonies of Dr. Luis Larion for the prosecution and Dr. Angelo Singian for the defense established beyond doubt that the death of the victim was due to profuse hemorrhage brought about by laceration of the vagina caused by a stiffened male organ or the insertion of a hard blunt object. The extrajudicial confession was fully corroborated by proof of the corpus delicti, making it sufficient to support conviction.
• Drug Addiction as Defense: The accused's testimony that he was prompted to rape the victim because he was not in his right senses as an addict is no defense at all. Drug addiction is punishable by law, and nobody should profit therefrom. The accused gave coherent answers in his extrajudicial confession and was able to re-enact the crime, demonstrating he could recall the events that transpired and was not so impaired as to lack criminal responsibility. That he did not intend to kill the victim was of no moment, as a person who performs a criminal act is responsible for all the consequences of said act regardless of his intention.

• Plea of Guilty to Capital Offense — A plea of guilty to a capital offense must be accepted only after the trial court has taken sufficient precautions to ensure the accused fully understands the nature of the charge and the consequences of the plea, including the maximum penalty imposable. The court must use language the accused can comprehend, and the accused must be given opportunity to withdraw the plea. In this case, the trial court's thorough questioning at arraignment and at subsequent hearings, its use of simple language, and its reading of the information in the vernacular satisfied these requirements.
• Extrajudicial Confession Corroborated by Corpus Delicti — An extrajudicial confession, when corroborated by proof of the corpus delicti, is sufficient to support conviction even independent of a plea of guilty. The corpus delicti may be established through medical and testimonial evidence proving both the occurrence of the criminal act and the accused's responsibility for it.
• Criminal Responsibility for All Consequences — A person who performs a criminal act is responsible for all the consequences of said act regardless of his intention. The absence of intent to kill does not exculpate where the death results from the rape committed by the accused.
• Drug Addiction as No Defense — Drug addiction is punishable by law and cannot serve as a defense to criminal liability. A person should not profit from his own criminal conduct of drug addiction to escape responsibility for crimes committed under its influence.

• "Drug addiction is punishable by law. Nobody should profit therefrom." — This passage rejects drug addiction as a defense to criminal liability, establishing that voluntary drug use cannot shield an offender from the consequences of his criminal acts.
• "A person who performs a criminal act is responsible for all the consequences of said act regardless of his intention." — This articulates the principle of criminal responsibility for all natural and logical consequences of a criminal act, applied here to reject the accused's claim that he did not intend to kill the victim.
• "The extra-judicial confession shows that he gave coherent answer to the questions propounded to him. Moreover, the accused re-enacted the commission of the crime. He could not have recalled the events that transpired if he was not in his right senses when he committed the crime." — This reasoning refutes the defense of drug addiction by pointing to the accused's coherent confession and ability to re-enact the crime as evidence that he was not so impaired as to negate criminal responsibility.

• People vs. Renegade, 57 SCRA 275 — Cited as supporting authority for the principle that a person who performs a criminal act is responsible for all the consequences of said act regardless of his intention.

• Article 335, last paragraph, Revised Penal Code — Imposes the death penalty when by reason of the rape, a homicide is committed. Applied as the controlling provision under which the accused was charged and convicted.
• Article 63, Revised Penal Code — Provides that death, as a single indivisible penalty, is applied regardless of mitigating or aggravating circumstances. Referenced in Justice Aquino's concurring opinion to explain the mandatory nature of the death penalty for rape with homicide.
• Presidential Decree No. 603 (Child and Youth Welfare Code), Articles 189 and 192 — Governed the treatment of youthful offenders. The trial court reopened the case to determine the accused's marital status, which was material to the application of these provisions.
• Presidential Decree No. 1179 — Amended Article 189 of PD 603 by lowering the age threshold for youthful offenders from twenty-one to eighteen years. Referenced in Justice Aquino's concurring opinion as potentially applicable retroactively to the accused, who was over twenty-one at the time of the Supreme Court decision.
• Article 13, paragraphs 3, 9, and 10, Revised Penal Code — Mitigating circumstances of lack of intent to commit so grave a wrong, illness of the offender diminishing will power, and analogous circumstances. Referenced in Justice Makasiar's concurring opinion as grounds for recommending executive commutation.

Barredo, Antonio, Muñoz Palma, Concepcion, Jr., Santos, Fernandez, and Guerrero, JJ., concur. Castro, C.J., concurs in the result. Teehankee, J., concurs in the separate opinion of Justice Makasiar. Fernando, J., took no part.

• Aquino, J. — Concurred, noting that the case is covered by the last paragraph of Article 335 of the Revised Penal Code imposing the death penalty for rape with homicide, and that death as a single indivisible penalty is applied regardless of mitigating or aggravating circumstances under Article 63. Further noted that Presidential Decree No. 1179, which lowered the youthful offender age threshold from twenty-one to eighteen, may be applied retroactively to the accused who was over twenty-one at the time of the decision.
• Makasiar, J. — Concurred but strongly recommended executive commutation of the sentence from death to life imprisonment, citing two mitigating circumstances: lack of intent to commit so grave a wrong as that committed, and illness of the offender (drug addiction) diminishing the exercise of will power without depriving him of consciousness of his acts. Reasoned that the accused's statement that the victim died by accident while struggling and that he was an addict was uncontradicted, and that the accused, being a newly married young man of twenty, was under the influence of drugs that excited his sexual impulses beyond control. Cited American jurisprudence on criminal responsibility under the influence of drugs and invoked the executive prerogative of mercy, noting the accused could still be rehabilitated.