People v. Burlado
REITERATIONFacts
The Antecedents: On December 18, 1920, a complaint was filed charging the defendant with qualified theft for allegedly taking $120 on April 11, 1920, in Manila. The complaint alleged aggravating circumstances: commission in the dwelling of the offended party, commission at nighttime, and four prior convictions for theft. Procedural History: The defendant was arrested, arraigned, and initially pleaded not guilty. During the trial, he withdrew his plea and substituted it with a plea of guilty. The Court of First Instance of Manila, considering the plea of guilty and the facts in the complaint, sentenced the defendant to two years, eleven months, and eleven days of presidio correccional, with accessory penalties, to indemnify the offended party $60, and to suffer subsidiary imprisonment in case of insolvency. The Petition: The defendant appealed the sentence, contending that the lower court erred in considering the aggravating circumstance of four prior convictions.
Issue(s)
Whether the lower court erred in considering the aggravating circumstance of prior convictions when the defendant pleaded guilty. Whether the penalty imposed by the lower court was in accordance with law, considering the facts alleged and admitted.
Ruling
The Supreme Court modified the sentence imposed by the lower court. The appellant was sentenced to be imprisoned for a period of six years and one day of presidio mayor, with accessory penalties, to indemnify the offended party in the sum of $60, and to pay the costs.
Ratio Decidendi
On the issue of considering prior convictions: A plea of guilty is an admission of all the material facts alleged in the information. When the information charges not only the crime but also that the defendant had been convicted theretofore, a plea of guilty to the charge admits not only the facts constituting the crime with which he is charged in the present case but also the fact that he had been convicted theretofore in the manner charged in the complaint. The defendant's plea of guilty not only admitted that he had committed the theft described in the body of the complaint but also admitted the fact that he had been convicted four different times for the crime of theft theretofore in the same court in which the present complaint was presented. Therefore, the lower court did not err in considering the aggravating circumstance of former convictions. On the penalty imposed: An appeal from a judgment of conviction based upon a plea of guilty raises no question of fact. This court will look to the record only for the purpose of ascertaining whether the penalty imposed is in accordance with the law based upon the facts alleged in the complaint. The essence of the plea of guilty in a criminal trial is that the accused admits his guilt freely, voluntarily, and with full knowledge of the consequences and meaning of his act, and with a clear understanding of the precise nature of the crime or crimes charged in the complaint or information. A plea of guilty, when formally entered on arraignment, is sufficient to sustain a conviction of any offense charged in the information without the introduction of further evidence, the defendant himself having supplied the necessary proof by his plea of guilty. Considering the amount of money stolen ($120 or P240) and that only $60 was recovered, the appellant must be sentenced in accordance with paragraph 3 of article 518 in relation with paragraph 3 of article 520 of the Penal Code, or with the immediate superior grade to that fixed in paragraph 3 of article 518 in its maximum degree, which is six years and one day to eight years of presidio mayor. The sentence of the lower court was modified to six years and one day of presidio mayor.
Main Doctrine
A plea of guilty admits all material facts alleged in the information, including aggravating circumstances such as prior convictions, and is sufficient to sustain a conviction without further evidence.