People v. Aling
REITERATIONFacts
The Antecedents: Norija T. Mohamad was stabbed on January 28, 1972, at Calarian, Zamboanga City, and died two days later. The accused, Airol Aling, her husband, admitted to the police that he stabbed his wife because he was informed in prison that she was living with another man and being unfaithful. Airol was an escapee from San Ramon Prison and Penal Farm at the time of the incident. He claimed he went to his father's house to reconcile with his wife, but she ran away upon seeing him, and he pursued and stabbed her. Procedural History: Airol Aling was charged with parricide. He was an escaped convict serving sentence for robbery with frustrated homicide. He initially signified willingness to plead guilty without a lawyer. After several postponements and with the assistance of counsel de oficio, he pleaded guilty to the information, which was translated into the Tausug dialect. He was placed on the witness stand and affirmed his guilty plea, understanding the consequences, including the possibility of a death sentence. The trial court sentenced Airol Aling to death and to pay indemnity. The Petition: The case was elevated to the Supreme Court for automatic review of the death penalty. Counsel for the accused contended that the marriage was not proven and that the accused did not fully understand the consequences of his plea. The Supreme Court affirmed the conviction but modified the penalty.
Issue(s)
Whether the marriage between the accused and the victim was sufficiently proven. Whether the accused fully understood the nature and consequences of his plea of guilty. Whether the penalty of death is appropriate given the circumstances, including the plea of guilty, the accused's status as an escaped convict, and the aggravating circumstance of quasi-recidivism.
Ruling
The Supreme Court affirmed the trial court's judgment of conviction for parricide but modified the penalty from death to reclusion perpetua due to the lack of the required number of votes for the imposition of the death penalty. The accused was ordered to pay indemnity to the heirs of the victim.
Ratio Decidendi
On whether the marriage between the accused and the victim was sufficiently proven: The Court held that the marriage was sufficiently proven. The accused's own testimony admitting he killed his wife, whom he married according to Muslim rites, constituted an admission against his penal interest. This was further supported by the presumption of marriage (semper praesumitur matrimonio) and the presumption that a man and woman deporting themselves as husband and wife have entered into a lawful contract of marriage. The existence of five children and the reference to a father-in-law also implied a lawful marital status. The accused's resentment of his wife's infidelity and neglect further confirmed their marital relationship. On whether the accused fully understood the nature and consequences of his plea of guilty: The Court found that the accused fully understood the nature and consequences of his plea. The trial judge, who was Muslim, took pains to follow the rule requiring evidence to be received even with a guilty plea in a capital case to ensure the accused's understanding. The arraignment was postponed multiple times to allow his counsel to confer with him and explain the consequences. The accused testified, his confession and police affidavits were presented, and he explicitly stated he understood that a guilty plea could lead to a death sentence, especially given his status as an escaped convict. He was not coerced or cajoled into pleading guilty. On whether the penalty of death is appropriate: The Court affirmed the conviction for parricide. However, while the trial court imposed the death penalty, the Supreme Court, after deliberation, found that only eight Justices voted for the death penalty, which was one vote short of the required majority for its imposition. Therefore, the penalty was modified to reclusion perpetua. The Court rejected the contention that the crime was mitigated by the plea of guilty or lack of intention to commit so grave a wrong, as the accused was a quasi-recidivist. His escape to kill his wife demonstrated perversity and incorrigibility, and his status as a non-Christian did not extenuate the heinousness of the offense, especially since he had attained some education and prior employment.
Main Doctrine
The penalty for parricide committed by an escaped convict who pleads guilty, where the crime is aggravated by quasi-recidivism, is reclusion perpetua, not death, due to lack of the required number of votes for the imposition of the death penalty.