Esguerra v. People
REITERATIONFacts
The Antecedents: Francisco Esguerra was accused of murder qualified by evident premeditation in the Court of First Instance of Bulacan. He was found guilty but was given the benefit of two mitigating circumstances: voluntary surrender and intoxication which was not habitual or intentional. Procedural History: The trial court sentenced Francisco Esguerra to suffer imprisonment of ten (10) years and one (1) day, as minimum, to twelve (12) years, as maximum. The accused appealed the sentence. The Petition: Francisco Esguerra filed a petition before the Supreme Court, claiming that the respondent judge erred in the application of the law regarding the correct penalty to be imposed, specifically in the presence of two mitigating circumstances and the application of the Indeterminate Sentence Law. He prayed for a modification of the sentence such that the minimum penalty would be four (4) years, two (2) months, and one (1) day of prision correccional.
Issue(s)
Whether the respondent judge erred in the application of the law with respect to the correct penalty to be imposed in the presence of two (2) mitigating circumstances and applying the Indeterminate Sentence Law.
Ruling
The Supreme Court partly granted the petition, modifying the prison sentence imposed on the petitioner. He shall suffer an indeterminate sentence of 8 years and 1 day of prision mayor, as minimum, to 12 years of prision mayor as maximum.
Ratio Decidendi
On Whether the respondent judge erred in the application of the law with respect to the correct penalty to be imposed in the presence of two (2) mitigating circumstances and applying the Indeterminate Sentence Law: The Supreme Court found merit in the petition. The penalty for murder is reclusion temporal in its maximum period to death. However, considering the presence of two mitigating circumstances (voluntary surrender and intoxication) and the absence of any aggravating circumstance, the penalty should be one degree lower, which is prision mayor in its maximum period to reclusion temporal in its medium period, ranging from 10 years and 1 day to 17 years and 4 months. Applying the Indeterminate Sentence Law, the maximum penalty imposed by the respondent judge (12 years) was correct as it fell within this range. However, the minimum of the indeterminate sentence should be one degree lower than the modified penalty, which translates to prision correccional in its maximum period to prision mayor in its minimum period, ranging from 4 years, 2 months, and 1 day to 10 years. The minimum penalty of 10 years and 1 day imposed by the respondent judge was incorrect as it fell outside this permissible range. The Office of the Solicitor General recommended a minimum sentence of 8 years and 1 day, which is within the correct range. Therefore, the Court modified the sentence to an indeterminate sentence of 8 years and 1 day of prision mayor, as minimum, to 12 years of prision mayor as maximum.
Main Doctrine
When two mitigating circumstances are present and no aggravating circumstances, the penalty prescribed by law should be lowered by one degree. Subsequently, the Indeterminate Sentence Law must be applied to determine the minimum and maximum periods of the sentence. The maximum of the indeterminate sentence is fixed within the range of the modified penalty, while the minimum is determined by taking a penalty one degree lower than the modified penalty.