People v. Derilo
REITERATIONFacts
The Antecedents: Accused-appellant Isidoro Baldimo y Quillo, along with Roman Derilo, Lucas Doños, Alejandro Cofuentes, and John Doe, were charged with murder committed by a band. The information alleged that on January 1, 1982, the accused, with treachery and evident premeditation, confederating and mutually helping one another, shot and stabbed Perpetua Adalim, causing her death. Procedural History: Only Isidoro Baldimo was apprehended. At his arraignment, he pleaded not guilty. However, after the prosecution presented its evidence, he withdrew his plea and entered a plea of guilty. The trial court, after a searching inquiry, convicted him of murder and sentenced him to death. The case was brought before the Supreme Court for automatic review. The Petition: The accused-appellant, in a brief pleading, merely asked for the modification of the death penalty to life imprisonment, contending that his belated acknowledgment of culpability should be treated as a mitigating circumstance by analogy. He also questioned the appreciation of evident premeditation as an aggravating circumstance.
Issue(s)
Whether the belated plea of guilty of the accused-appellant can be considered a mitigating circumstance. Whether evident premeditation was sufficiently proven as an aggravating circumstance. Whether the death penalty imposed by the trial court is still applicable given the provisions of the 1987 Constitution and subsequent laws.
Ruling
The judgment of the trial court is MODIFIED. Accused-appellant Isidoro Q. Baldimo is sentenced to suffer the penalty of reclusion perpetua and to indemnify the heirs of the victim in the amount of P50,000.00.
Ratio Decidendi
On the issue of the belated plea of guilty as a mitigating circumstance: The Court held that a belated plea of guilty, entered after the prosecution has presented its evidence, cannot be considered a mitigating circumstance under Article 13 of the Revised Penal Code. The rationale behind considering a plea of guilty as mitigating is the accused's spontaneous admission of guilt at the first opportunity as an act of repentance. Allowing an accused to plead not guilty initially and then change their plea after seeing the strength of the prosecution's case would permit speculation on the outcome of the proceedings. The Court distinguished this from cases where a plea of guilty is considered mitigating because it is entered at the earliest possible stage of the proceedings, signifying genuine remorse and a desire to reform. On the issue of evident premeditation as an aggravating circumstance: The Court ruled that evident premeditation was not sufficiently proven. The trial court erred in concluding that evident premeditation was present based solely on the appellant's plea of guilty and the existence of conspiracy. To establish evident premeditation, there must be proof of the time the offender determined to commit the crime, an act indicating adherence to that determination, and a sufficient lapse of time for reflection. The records were barren of any proof showing how and when the plan to kill was hatched or the time elapsed between determination and execution. The Court reiterated that aggravating circumstances must be proven with the same certainty as the crime itself and cannot be presumed or inferred from conspiracy alone, as their elements are distinct. On the applicability of the death penalty and the 1987 Constitution: The Court found that the death penalty imposed by the trial court could not be carried out. Firstly, Republic Act No. 7659, which imposed the death penalty for heinous crimes, was enacted after the commission of the crime in 1982 and thus could not be applied retroactively to the prejudice of the accused. Secondly, and more importantly, Section 19 of the 1987 Constitution mandates that any death penalty already imposed shall be reduced to reclusion perpetua, unless Congress provides otherwise for compelling reasons involving heinous crimes. The Court clarified that this reduction is automatic and does not require presidential commutation or further legislative action for its effectivity. Therefore, the death sentence imposed on the appellant in 1986 was automatically reduced to reclusion perpetua upon the ratification of the 1987 Constitution.
Main Doctrine
A belated plea of guilty, entered after the prosecution has presented its evidence, cannot be considered a mitigating circumstance. Furthermore, for evident premeditation to be appreciated as an aggravating circumstance, it must be proven by evidence, and cannot be presumed from a plea of guilty or from the existence of conspiracy alone. The 1987 Constitution mandates the reduction of any death penalty already imposed to reclusion perpetua.