People v. Intal
REITERATIONFacts
The Antecedents: The appellant was initially on trial for the offense of double murder. During the proceedings, he manifested a willingness to plead guilty to the lesser offense of double homicide. Procedural History: After the prosecution had rested its case and the defense had presented witnesses, the accused sought to withdraw his plea of not guilty to double murder and substitute it with a plea of guilty to double homicide. The prosecution agreed, and the information was amended accordingly. The accused, assisted by counsel, pleaded guilty to the amended charge of double homicide, also requesting to prove the mitigating circumstance of physical infirmity, which the prosecution admitted. The trial court subsequently sentenced the appellant to an indeterminate penalty for double homicide. The Petition: The appellant appealed the penalty imposed by the trial court, arguing that his plea of guilty to the amended charge of double homicide should have been considered a mitigating circumstance. The case was certified to the Supreme Court by the Court of Appeals due to the nature of the appeal concerning the penalty.
Issue(s)
Whether the plea of guilty to a lesser offense, after the prosecution has rested its case and the information has been amended, constitutes a mitigating circumstance. Whether the penalty imposed by the trial court was correct, considering the mitigating circumstances.
Ruling
The Supreme Court modified the penalty imposed by the trial court. It ruled that the plea of guilty to the amended charge of double homicide should be considered a mitigating circumstance. With two mitigating circumstances (plea of guilty and physical infirmity) and no aggravating circumstances, the penalty should be one degree lower than that prescribed by law for double homicide, applied in its maximum period due to the complex nature of the offense. The Court imposed an indeterminate penalty of not less than 4 years, 9 months and 11 days of prision correccional, and not more than 10 years, 8 months and 1 day of prision mayor.
Ratio Decidendi
On Issue 1: The Supreme Court held that the plea of guilty to the amended charge of double homicide should be considered a mitigating circumstance. The Court distinguished this case from People vs. Noble, where only an offer to plead guilty was made. In the present case, the accused actually entered a plea of guilty to the amended information after it was formally changed from double murder to double homicide, with the prosecution's agreement. The Court cited People vs. Calma as a precedent where a similar plea was taken into account as a mitigating circumstance. Therefore, following Calma, the plea of guilty in this instance was correctly recognized as an extenuating circumstance. On Issue 2: The Supreme Court found that the penalty imposed by the trial court was incorrect. The Court noted that there were two mitigating circumstances: the plea of guilty to the amended charge and the admitted physical infirmity of the accused. There were no aggravating circumstances alleged in the amended information. According to Article 13 of the Revised Penal Code, when there are mitigating circumstances and no aggravating circumstances, the penalty should be one degree lower than that prescribed by law. For double homicide, the prescribed penalty is reclusion temporal. One degree lower is prision mayor. However, the Court also considered the complex nature of the offense and applied the penalty in its maximum period, as per People vs. Gonzales. Applying the Indeterminate Sentence Law, the maximum of prision mayor is 10 years and 1 day to 12 years, and the minimum is the maximum period of prision correccional, which is 4 years, 2 months, and 1 day to 6 years. The Court ultimately modified the penalty to an indeterminate sentence of not less than 4 years, 9 months and 11 days of prision correccional, and not more than 10 years, 8 months and 1 day of prision mayor.
Main Doctrine
The Supreme Court reiterated that a plea of guilty to a lesser offense, as distinguished from a mere offer to plead guilty, can be considered as a mitigating circumstance under Article 13 of the Revised Penal Code. This is particularly true when the prosecution agrees to the amendment of the information and the accused formally enters the plea. Consequently, the penalty should be imposed based on the offense charged in the amended information, and the mitigating circumstance should be applied to lower the penalty by one degree.