G.R. No. 130372 . July 20, 1999.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GUIAMAD MANTUNG, accused-appellant.

FACTS

Accused-appellant Guiamad Mantung, a security guard, was charged with the complex crime of Robbery with Homicide. The prosecution established that on August 10, 1996, the Cebuana Lhuiller Pawnshop branch in Parañaque failed to open. Upon investigation, managers found the bodies of two employees, Renjie Balderas and Maribel Mayola, inside the vault room. Cash and jewelry worth millions were missing. Critical evidence included two handwritten letters found at the scene. One letter, addressed to a manager and written in Filipino, was signed by Mantung. In it, he confessed to killing the victims because they gave him pork, which his Muslim faith forbade, and admitted taking the money and jewelry because he needed it. Another letter to his wife, in Muslim script, was also found. The defense presented an alibi, claiming Mantung was elsewhere, but this was uncorroborated.

ISSUE

The core issue is whether the trial court erred in convicting Mantung of Robbery with Homicide and in imposing the death penalty based on the appreciation of the aggravating circumstances of evident premeditation and treachery.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The letters of confession constitute a valid extrajudicial confession, which is admissible as evidence of guilt. An extrajudicial confession, if corroborated by evidence of corpus delicti (the fact that a crime was committed), is sufficient to sustain a conviction. Here, the corpus delicti—the deaths of the victims and the loss of property—was conclusively established by the discovery of the bodies and the emptied vault. Mantung’s confession was detailed, voluntary, and corroborated by this physical evidence. His alibi, being weak and unsupported, deserved no credence.
However, the Court deleted the aggravating circumstances of evident premeditation and treachery. For evident premeditation, the prosecution failed to prove the essential elements: the time when the accused decided to commit the crime, an act manifestly indicating his perseverance, and a sufficient lapse of time between the decision and execution. The mere fact he moved out of his rented room a day prior is insufficient and, in this instance, based on hearsay. For treachery, there was a complete absence of evidence detailing the manner of attack. The medical findings showed the victims were shot at close range, but no witness described how the assault began or was carried out. Treachery cannot be presumed. Consequently, with no aggravating circumstances present, the proper penalty is reclusion perpetua. The award of moral and exemplary damages was also deleted for lack of legal basis. The decision was affirmed with modifications.