People v. Acaya
REITERATIONFacts
The Antecedents: On the evening of July 16, 1983, during a wedding celebration in Barangay San Vicente, Ibana, Batanes, Victor Abad was stabbed on the left side of the abdomen by Angel Acaya. Victor Abad was rushed to the Batanes Hospital where he expired the following day, July 17, 1983, at 3:00 p.m. The cause of death was acute renal shutdown hemorrhage due to a severe stab wound. Before his death, Victor Abad identified Angel Acaya as his assailant. The accused, Angel Acaya, was found by the police lying on a porch, heavily intoxicated and asleep. He had no recollection of the events of the previous evening. Procedural History: An Information for Murder was filed against Angel Acaya, alleging the aggravating circumstances of treachery, evident premeditation, and ignominy. Upon arraignment, the accused, assisted by counsel, voluntarily entered a plea of guilty. The Regional Trial Court of Basco, Batanes, Branch XIII, finding the accused guilty beyond reasonable doubt of Murder, sentenced him to reclusion perpetua, to indemnify the heirs of the victim, and to pay damages and costs. The Petition: The accused appealed the decision of the Regional Trial Court, assigning several errors, including grave abuse of discretion in denying a motion to reconsider the plea of guilty to not guilty, and errors in the appreciation of aggravating and mitigating circumstances.
Issue(s)
Whether the trial court erred in denying the request to reconsider the plea of guilty to not guilty. Whether the trial court erred in not giving due course to the notice of appeal. Whether the trial court erred in concluding that ignominy was proven; and whether treachery and evident premeditation were duly proven. Whether the prosecution proved intent to kill beyond the questioned plea of guilty, considering the accused's intoxication. Whether the mitigating circumstance of voluntary surrender should have been appreciated. Whether the mitigating circumstances of a plea of guilty should be considered in determining the penalty.
Ruling
The appealed judgment is modified. Angel Acaya is sentenced to suffer an indeterminate penalty of ten (10) years and one (1) day of prision mayor, as minimum, to seventeen (17) years, four (4) months and one (1) day of reclusion temporal, as maximum. He is ordered to indemnify the heirs of the victim, Victor Abad, in the amount of P30,000.00. The rest of the judgment is affirmed.
Ratio Decidendi
On the denial of reconsideration of the plea of guilty: The Court found that the claim of the defense counsel that he requested a reconsideration of the plea of guilty to not guilty was not borne out by the records. Furthermore, the trial court had informed the appellant of the possibility of the death penalty, and any change to a lesser penalty in the written decision was more favorable to the appellant. The presumption of regularity in the performance of official duty by the stenographer was upheld in the absence of proof of deletion or tampering of stenographic notes. On the appreciation of aggravating circumstances (treachery, evident premeditation, ignominy): The Court ruled that treachery was present due to the suddenness of the attack while the victim was dancing, leaving him no chance to defend himself. However, evident premeditation was not appreciated as its elements (time of determination, overt acts, lapse of time for reflection) were not sufficiently proven. The presence of another knife on the appellant was not proof of "a cold and deep meditation." Ignominy was also not appreciated, as the commission of the crime in a public place did not necessarily add disgrace or obloquy to the material injury. On the effect of the plea of guilty, treachery, and evident premeditation: The Court clarified that a plea of guilty does not automatically establish aggravating circumstances like treachery and evident premeditation if the evidence does not support them, citing People vs. Gravino. The conviction was based not solely on the plea but on the evidence presented by the prosecution, which included testimonies of eyewitnesses and the victim's ante mortem statement. On intent to kill and intoxication: The Court found the averment of inexistent intent to kill due to intoxication unmeritorious. While the accused was drunk after the incident, prosecution eyewitnesses did not notice his intoxication at the precise time of the stabbing. The act of stabbing with a deadly weapon, causing a severe and penetrating wound, indicated an intent to kill. The burden to rebut the presumption of unlawful intent was not satisfactorily discharged. On voluntary surrender: The mitigating circumstance of voluntary surrender was not proven. There was no showing that the surrender was spontaneous or that the accused intended to submit himself to authorities. The defense itself stressed the appellant's intoxication when apprehended, and mere lack of resistance cannot be equated with voluntary surrender. On the penalty: The crime committed was Murder, qualified by treachery, and attended by the mitigating circumstance of a plea of guilty. Pursuant to Article 248 of the Revised Penal Code, the imposable penalty for Murder is reclusion perpetua. However, considering the 1987 Constitution, the penalty is now reclusion temporal in its maximum period to reclusion perpetua. The Court imposed an indeterminate penalty of ten (10) years and one (1) day of prision mayor to seventeen (17) years, four (4) months and one (1) day of reclusion temporal.
Main Doctrine
A plea of guilty to a charge of murder, while admitting the commission of the unlawful act, does not automatically establish the presence of aggravating circumstances like treachery and evident premeditation if the evidence adduced does not adequately disclose their existence. The court must still require presentation of evidence to determine the degree of culpability and the presence of qualifying or modifying circumstances.