GR 53570; (July, 1981) (Digest)
G.R. No. L-53570 July 24, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARMANDO MATILLA alias MANDO, accused.
FACTS
The accused, Armando Matilla, was charged with Highway Robbery with Homicide under Presidential Decree No. 532 for the killing of Marina Cano Llantada on a national highway in Calbayog City on May 19, 1979. The victim was found with fatal stab wounds, and money was missing from her person. Following his arrest, Matilla gave an extrajudicial confession during custodial interrogation where he admitted to stabbing the victim and taking two pesos. He initially pleaded guilty at arraignment but later withdrew it and entered a plea of not guilty. Before trial, however, he withdrew his not guilty plea and reinstated his original plea of guilty.
ISSUE
The core issue for automatic review is whether the conviction based on the plea of guilty and the extrajudicial confession, and the imposition of the death penalty, are legally valid.
RULING
The Supreme Court affirmed the conviction but modified the penalty. The Court first ruled that the extrajudicial confession was inadmissible as evidence. It was obtained in violation of the constitutional rights during custodial interrogation, specifically the right to be informed of the right to remain silent and to counsel. The prosecution failed to prove a voluntary, knowing, and intelligent waiver of these rights. However, the judicial confession arising from Matilla’s second plea of guilty was valid and sufficient to sustain his conviction. The Court found he entered this plea fully cognizant of its consequences, especially after the fiscal refused his request to change the charge to murder. This judicial confession, coupled with the established corpus delicti from other prosecution evidence, removed any reasonable doubt as to his guilt for the special complex crime of highway robbery with homicide. While the law prescribes the death penalty, the Court commuted it to reclusion perpetua as the requisite votes for affirmance of the capital punishment could not be obtained.