GR L 63251; (December, 1983) (Digest)
G.R. Nos. L-63251-52, December 29, 1983
People of the Philippines, Plaintiff-Appellee, v. Alexander de la Fuente y Mahilum, Accused.
FACTS
The accused, Alexander de la Fuente, was charged with the complex crime of double murder with frustrated murder for the fatal stabbing of his common-law wife, Elvira Dumapig, and her mother, Matilde Dumapig, and the wounding of Elvira’s sister, Imelda. The killings occurred in the victims’ home in Dipolog City. De la Fuente initially pleaded not guilty but later changed his plea to guilty for both murder charges and a separate charge of frustrated murder. To ensure the plea was informed and voluntary, the trial judge conducted a rigorous inquiry, and the prosecution still presented evidence, including the eyewitness account of Imelda and the accused’s own extrajudicial confession. In his testimony, de la Fuente claimed he was provoked by an altercation earlier that day involving money and a physical attack by Elvira.
ISSUE
The principal issue for automatic review was the correctness of the imposition of the death penalty, requiring an assessment of the proper penalties by evaluating the presence of mitigating and aggravating circumstances.
RULING
The Supreme Court affirmed the conviction but modified the penalties. The Court found the crimes to be two separate murders and attempted murder, not a complex crime. For each murder, the qualifying circumstance of treachery was present, as the victims were stabbed while asleep. The Court rejected the mitigating circumstance of passion and obfuscation. The alleged provocation—a quarrel over money and a bite hours before the killing—was too remote, providing ample time for reflection, which instead established the aggravating circumstance of evident premeditation. The commission of the crime in the victims’ dwelling, not the accused’s, was also aggravating. However, the plea of guilty and voluntary surrender were valid mitigating circumstances. Offsetting these, the Court imposed reclusion perpetua for each murder. For the crime against Imelda, correctly classified as attempted murder with treachery but without other aggravants, and with two mitigating circumstances, the penalty was six months of arresto mayor. The civil indemnity was increased to P30,000 for each set of heirs of the deceased victims.