People v. Halasan
REITERATIONFacts
The Antecedents: On January 16, 1959, an armed band of more than four men, including appellant Policarpio Halasan, attacked the store used as a residence of Maximino Maghuyop. They forcibly entered the premises by detaching a wooden board from the kitchen wall, firing guns which killed Leoncio Balaobao and wounded Maximino Maghuyop. After gaining entry, they hogtied the occupants, demanded cash from Maximino Maghuyop and his wife Angela C. Maghuyop, and took cash amounting to P1,200.00 and merchandise valued at P89.75, totaling P1,289.75. Procedural History: An information was filed charging Policarpio Halasan and thirteen others with robbery in band with homicide and frustrated homicide. Only four were apprehended. One of the apprehended accused, Teotimo Montalla, was discharged to be a state witness. During the cross-examination of Montalla, Halasan, through his counsel, manifested his willingness to change his plea from not guilty to guilty. The court a quo, after warning Halasan of the consequences, allowed the change of plea. The court did not credit the plea of guilty as a mitigating circumstance, considering it was entered after the presentation of evidence and due to the accused's confession of depravity and habitual delinquency. The court imposed the death penalty, indemnification for the deceased's heirs, and payment for the stolen articles. The Petition: This case is an automatic review of the decision of the Court of First Instance of Zamboanga del Sur. The appellant's counsel argued that the plea of guilty should be a mitigating circumstance, warranting a lower penalty. The Solicitor General maintained that the lower court correctly imposed the penalty.
Issue(s)
Whether the plea of guilty, entered after the prosecution had begun presenting its evidence, can be considered a mitigating circumstance. Whether the penalty imposed by the lower court, the death penalty, is proper for the crime of robbery in band with homicide.
Ruling
The Court affirmed the decision of the lower court with modification. The plea of guilty was not considered a mitigating circumstance. The death penalty was imposed by the lower court, but due to the lack of the requisite number of votes, the penalty was modified to reclusion perpetua.
Ratio Decidendi
On the issue of the plea of guilty as a mitigating circumstance: The Court ruled that a plea of guilty entered after the prosecution has commenced the presentation of its evidence cannot be considered a mitigating circumstance. This is a well-established principle in jurisprudence, as reiterated in cases such as People vs. Co Chang, People vs. De la Cruz, and People vs. Lambino. The rationale is that such a plea, made at a later stage of the proceedings, may be motivated by a desire to gain leniency rather than a genuine admission of guilt at the earliest opportunity. Therefore, the lower court correctly did not credit the plea of guilty as a mitigating circumstance in favor of the accused. On the issue of the penalty for robbery in band with homicide: The Court agreed with the Solicitor General that the penalty for robbery in band with homicide is reclusion perpetua to death, as provided for in Article 294 of the Revised Penal Code. Furthermore, in accordance with Republic Act No. 12, when the crime is robbery in band with homicide, the penalty to be imposed is the maximum penalty, which is death, even without the concurrence of any aggravating circumstance. The Court also noted that by pleading guilty, the accused is deemed to have admitted all material allegations in the information, including any aggravating circumstances. The aggravating circumstance of "band" is inherent in the crime of robbery in band. Therefore, the imposition of the death penalty by the lower court was in accordance with law.
Main Doctrine
A plea of guilty entered after the prosecution has commenced the presentation of its evidence cannot be considered a mitigating circumstance. The penalty for robbery in band with homicide is reclusion perpetua to death, and in accordance with Republic Act 12, the maximum penalty, death, should be imposed even without the concurrence of any aggravating circumstance, unless the required number of votes for death is not met, in which case reclusion perpetua shall be imposed.