G.R. No. L-20953; April 21, 1969
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FELIPE VILLAS Y TANTI, defendant-appellant.

FACTS

Felipe Villas y Tanti, a 27-year-old single man, was employed for almost four years as a “house boy” or helper by Catalina Colman, a 47-year-old spinster, at her Afable Flower Shop on Taft Avenue, Manila. He lived on the premises. On the evening of October 3, 1962, after the victim left to visit a hospital, the defendant re-entered the shop at 10 p.m., hid under her bed, and waited. When she returned and was in her room, he emerged, armed with a hammer, and struck her multiple times on the face and body. While she was still alive, he raped her. Afterwards, he stole cash amounting to P476.80 and jewelry from her belongings. He then hid the stolen items and attempted to clean up. The following morning, he reported a robbery. The victim died from extensive skull fractures and other injuries. An autopsy confirmed the fatal blows and the presence of spermatozoa. The defendant initially denied involvement but later confessed. He was charged with robbery with homicide and rape. After his initial plea of not guilty was withdrawn due to a language issue, he was re-arraigned in the “waray-waray” dialect and pleaded guilty. The trial court nonetheless received evidence on aggravating and mitigating circumstances. The court found him guilty and sentenced him to death, considering the aggravating circumstances of nocturnity and grave abuse of confidence, offsetting only one with the mitigating circumstance of a plea of guilty.

ISSUE

Whether the trial court erred in finding the presence of the aggravating circumstances of nocturnity and grave abuse of confidence and, consequently, in imposing the death penalty instead of reclusion perpetua.

RULING

The Supreme Court affirmed the trial court’s decision. The record, including the defendant’s undisputed confession, established that he purposely sought nighttime to commit the crime. He took advantage of the victim’s absence in the evening, re-entered the premises, hid, and committed the assault, rape, and robbery under cover of darkness, which facilitated the commission without detection by others in the premises. Regarding abuse of confidence, the defendant had served as a trusted house boy for nearly four years, with access to the victim’s private room and the shop, which he exploited to commit the crime. The Court agreed that his guilt for the complex crime of robbery with homicide and rape, committed under these aggravating circumstances, was proven beyond reasonable doubt. The death penalty was affirmed.