People v. Andaya
REITERATIONFacts
The Antecedents: The appellant, Rodolfo Andaya, was facing automatic review of a death sentence imposed by the Court of First Instance of Davao for murder. This was the second death sentence for the same offense, the first having been set aside by the Supreme Court due to an improvident plea of guilty. Procedural History: Following the Supreme Court's directive, a proper hearing was conducted. The appellant initially entered a conditional plea of guilty with a prayer for life imprisonment, which the trial court treated as a plea of not guilty. Subsequently, upon rearraignment, the appellant changed his plea to an unqualified plea of guilty, despite being fully apprised of the grave consequences, including the inevitability of the death penalty due to aggravating circumstances, specifically quasi-recidivism. The Petition: The defense presented evidence solely to prove mitigating circumstances. The prosecution presented witnesses, including the municipal judge who took the appellant's extra-judicial confessions, a police sergeant, the deputy chief of police who investigated the appellant, and an employee of the Davao Penal Colony who testified that the appellant was serving a sentence for imprisonment when he committed the murder. The defense invoked Article 297 of the Revised Penal Code, arguing the offense should be considered attempted robbery with homicide, punishable by reclusion perpetua. The Solicitor General countered that the killing was motivated by personal reasons, not robbery, and that the term 'homicide' in Article 297 could include murder.
Issue(s)
Whether the crime committed is murder or attempted robbery with homicide. Whether the aggravating circumstance of quasi-recidivism warrants the imposition of the death penalty despite the presence of mitigating circumstances.
Ruling
The Supreme Court affirmed the death sentence imposed by the trial court. It held that the killing was murder, not attempted robbery with homicide, and that the aggravating circumstance of quasi-recidivism made the death penalty unavoidable. However, the Court recommended the commutation of the death penalty to life imprisonment based on the appellant's exemplary conduct and industry as a prisoner, and the mitigating circumstances of voluntary surrender, intoxication, and voluntary plea of guilty.
Ratio Decidendi
On whether the crime committed is murder or attempted robbery with homicide: The Court found that the appellant's own admission, as evidenced by his extra-judicial confessions affirmed in court, indicated that the killing was motivated by personal reasons unrelated to robbery. The co-accused's suggestion of robbery was merely an inducement, and no robbery was committed in any of its stages. The appellant's statement revealed that the killing was a form of retaliation for the victim's alleged theft of a fighting cock. Therefore, the crime could not be classified as attempted robbery with homicide under Article 297 of the Revised Penal Code. The Court emphasized that the term 'homicide' in Article 297 is generic and can include murder if attended by qualifying circumstances, but in this case, the primary intent was not robbery, making the application of Article 297 inappropriate. The killing was established as murder due to the presence of aggravating circumstances alleged in the information. On whether the aggravating circumstance of quasi-recidivism warrants the imposition of the death penalty despite the presence of mitigating circumstances: The Court held that the undisputed fact that the appellant was serving a sentence for homicide when he committed the murder constituted quasi-recidivism. This circumstance, under Article 160 of the Revised Penal Code, alone renders the imposition of the death penalty unavoidable, notwithstanding the presence of mitigating circumstances such as voluntary surrender, intoxication, and the voluntary plea of guilty. The Court noted that the appellant entered his plea of guilty with full awareness of the legal consequences after being properly apprised by the trial court. The evidence, consisting mainly of the appellant's extra-judicial confessions, supported the finding that the killing was murder.
Main Doctrine
Quasi-recidivism, as an aggravating circumstance, renders unavoidable the imposition of the death penalty, even in the presence of mitigating circumstances, when the crime committed is murder.