People v. Villegas
REITERATIONFacts
The Antecedents: The defendant, Leoncio Villegas y Tuliao, was accused of attempted robbery in an inhabited house. The information alleged that on or about July 9, 1930, in the City of Manila, the accused, with intent of gain and against the owner's consent, unlawfully entered the dwelling of Miss S. H. Olson by forcibly breaking open the wire screen of a window. He commenced the commission of robbery by overt acts, intending to steal personal property valued at P1,000. His failure to accomplish this was not due to voluntary desistance but to timely detection and intervention by third persons who caused his arrest. The information also stated that the accused had been previously convicted eight times for theft and twice for estafa, making him a habitual delinquent under Act No. 3586. Procedural History: The defendant initially pleaded not guilty but later withdrew his plea and entered a plea of guilty. The trial court found him guilty of attempted robbery in an inhabited house, as well as recidivist and habitual criminal, sentencing him to two months' arresto mayor and twenty-one years' imprisonment under Act No. 3586. The Petition: The defendant appealed the judgment, assigning as errors the finding of guilt for robbery in an inhabited house and the imposition of the additional penalty under Act No. 3586.
Issue(s)
Whether the Information's allegation of 'intent of gain' is a mere conclusion that reduces the crime to trespass to dwelling. Whether the additional penalty for habitual delinquency under Act No. 3586 can be applied based on convictions that occurred prior to the law's enactment.
Ruling
The Supreme Court affirmed the judgment of the trial court, with modifications regarding accessory penalties. The Court held that the information was sufficient to charge attempted robbery in an inhabited house and that the plea of guilty was valid. The additional penalty for habitual delinquency was also upheld.
Ratio Decidendi
On Issue 1: The Court held that when the defendant pleaded guilty, he admitted the facts alleged in the Information, including the intent of gain. The Information sufficiently described the defendant's purpose by stating he intended to 'take, steal, and carry away' property valued at P1,000. Applying the rules from U.S. v. Salcedo and U.S. v. Go Changco, the Court noted that using the 'words of the law' in an Information is not a defect. The absence of a detailed list of property did not vitiate the judgment, as the defendant waived this objection by not demanding a bill of particulars at the trial level. Therefore, the acts constituted attempted robbery, not merely trespass to dwelling. On Issue 2: The Court ruled that Act No. 3586 was properly applied despite the prior convictions occurring before its enactment. It is a established principle in Philippine jurisdiction that for habitual delinquency laws to apply, it is only necessary that the latest crime be committed after the law became effective. The Court adopted the North American rule from 16 C.J. 1341, stating that a more severe penalty for a subsequent offense does not require the first conviction to occur after the statute's enactment. Because the attempted robbery occurred in 1930, after the law was in force, the status of habitual delinquency was correctly triggered. The additional imprisonment of 21 years was thus consistent with the legislative intent to punish persistent offenders.
Main Doctrine
A plea of guilty to an information alleging intent of gain and the commission of overt acts to achieve that purpose, coupled with the failure to accomplish the objective due to timely detection, is sufficient to establish attempted robbery in an inhabited house, and the subsequent conviction for habitual delinquency under Act No. 3586 is applicable even if prior offenses occurred before the law's enactment, provided the current offense was committed after its effectivity.