People v. Oandasan
REITERATIONFacts
The Antecedents: The accused, Mariano Oandasan, was charged with homicide. He initially pleaded not guilty during the preliminary investigation conducted by the Municipal Court of Flora, Mountain Province. The case was then elevated to the Court of First Instance of Cagayan for trial on the merits. Upon arraignment in the Court of First Instance, the accused pleaded guilty. Procedural History: Before sentencing, the accused presented evidence to prove the mitigating circumstances of incomplete self-defense and voluntary surrender, in addition to his plea of guilty. The trial court, however, disregarded the plea of guilty as a mitigating circumstance due to the prior plea of not guilty in the municipal court. It considered provocation and voluntary surrender as ordinary mitigating circumstances. The accused was sentenced to an indeterminate penalty for homicide and ordered to indemnify the heirs of the deceased. The Petition: The accused appealed, arguing that the penalty imposed was incorrect, specifically that his plea of guilty should have been considered a mitigating circumstance and that incomplete self-defense should have been appreciated as a privileged mitigating circumstance.
Issue(s)
Whether the plea of guilty in the Court of First Instance should be considered a mitigating circumstance despite a prior plea of not guilty in the municipal court during preliminary investigation. Whether the circumstances of the case constitute incomplete self-defense as a privileged mitigating circumstance. What is the proper penalty to be imposed considering the mitigating circumstances present.
Ruling
The Supreme Court modified the decision of the lower court. It ruled that the plea of guilty in the Court of First Instance should be considered a mitigating circumstance. It also found that the elements of incomplete self-defense were present, entitling the accused to a privileged mitigating circumstance. Consequently, the penalty was reduced by two degrees, and the accused was sentenced to an indeterminate penalty of four (4) months of arresto mayor as minimum, to two (2) years, four (4) months and one (1) day of prision correccional as maximum.
Ratio Decidendi
On the issue of the plea of guilty as a mitigating circumstance: The Court held that the plea of guilty entered during the preliminary investigation in the municipal court should not be held against the accused. This is because the municipal court only conducted a preliminary investigation and did not have jurisdiction to render a judgment on the charge of homicide. The Court emphasized that the purpose of the mitigating circumstance of confession of guilt is to reward spontaneous willingness to admit guilt, which is absent if the plea is made strategically after an initial plea of not guilty in a court without jurisdiction. The plea of guilty in the Court of First Instance, the court of competent jurisdiction, was therefore properly entered and should be considered as a mitigating circumstance. The Court stated, "For purposes of applying the mitigating circumstance of confession of guilt, the plea of not guilty upon arraignment at preliminary investigation in the municipal court is no plea at all." On the issue of incomplete self-defense: The Court found that the facts presented demonstrated unlawful aggression by the deceased, Quirino Duldulao, who chased the accused's son and then clubbed the accused. The accused's act of stabbing the deceased, while not entirely free from the element of reasonable necessity of the means employed to repel the aggression, sufficiently established the presence of incomplete self-defense. The Court noted that the deceased clubbed the accused on the head, prompting the accused to stab him. The Court concluded, "As we see it, the only element absent to exempt the accused totally from criminal liability under Article 11(1), Revised Penal Code, is '[r]easonable necessity of the means employed to prevent or repel' the unlawful aggression." On the proper penalty: The Court applied Article 69 of the Revised Penal Code, which allows for a penalty lower by one or two degrees when the deed is not wholly excusable due to the lack of some conditions for exemption, provided the majority of such conditions are present. In this case, incomplete self-defense qualified for this reduction. Furthermore, Article 64(5) of the Revised Penal Code mandates a penalty next lower to that prescribed by law when there are generic mitigating circumstances and no aggravating circumstances. The Court also considered the plea of guilty and voluntary surrender. Citing previous jurisprudence, the Court determined that a two-degree reduction of the penalty for homicide was warranted: one degree under Article 69 for incomplete self-defense, and another degree under Article 64(5) for the presence of mitigating circumstances. The penalty for homicide is reclusion temporal; two degrees lower is prision correccional. The Court fixed the penalty within the medium period of prision correccional. Applying the Indeterminate Sentence Law, the minimum penalty was set within the range of arresto mayor.
Main Doctrine
A plea of guilty entered during a preliminary investigation in a municipal court, which lacks jurisdiction over the offense, should not be held against the accused when he re-arraigns and pleads guilty in the Court of First Instance, as the municipal court's proceeding was merely investigatory and not one where a judgment could be rendered. The plea of guilty in the court of competent jurisdiction should be considered as a mitigating circumstance.