People v. Mangsant
REITERATIONFacts
The Antecedents: The accused-appellant was charged with murder for allegedly attacking Demetria Ferrer, a 14-year-old girl, with a knife, inflicting fatal wounds. The information alleged evident premeditation, disregard of sex, and abuse of superior strength. Procedural History: The Court of First Instance of Manila found the defendant guilty of murder and sentenced him to reclusion perpetua. During the trial, the defendant changed his plea from 'not guilty' to 'guilty' and testified that he killed the deceased because she revealed she loved another man, causing him to become 'obfuscated'. The Petition: The defendant appealed the judgment of the trial court.
Issue(s)
Whether the aggravating circumstances of evident premeditation, disregard of sex, and abuse of superior strength were correctly appreciated. Whether the mitigating circumstances of lack of instruction, obfuscation, and plea of guilty were correctly appreciated. Whether the penalty imposed by the trial court was in accordance with law.
Ruling
The judgment of the trial court was modified. The penalty was imposed in its minimum period, and the defendant was sentenced to an indeterminate sentence of ten (10) years of prison mayor to seventeen (17) years, four (4) months, and one (1) day of reclusion temporal, with accessories of the law, to indemnify the heirs of the deceased in the amount of P1,000, and to pay the costs of both instances.
Ratio Decidendi
On the aggravating circumstances: The Court agreed with the Solicitor General that evident premeditation was not proven. The aggravating circumstance of disregard of sex was not considered because there was no proof that the accused intended to offend or insult the sex of the victim. The aggravating circumstance of abuse of superior strength was also not taken into account, as it was considered inherent in the crime and absorbed by the treachery which qualified the crime as murder. The Court cited Viada and previous Supreme Court decisions to support the exclusion of these circumstances. On the mitigating circumstances: The Court ruled that the mitigating circumstance of lack of instruction could not be applied because the defendant admitted to having studied in the first grade. The circumstance of obfuscation was also not considered mitigating, as the revelation by the deceased that she loved another man was not deemed sufficient to produce the mental blindness required by law. The mitigating circumstance of a voluntary confession was acknowledged. On the penalty: The Court found the defendant guilty of murder. Considering the presence of the mitigating circumstance of voluntary confession and the absence of any aggravating circumstances to offset it, the penalty prescribed for murder (reclusion temporal in its maximum period to death) was imposed in its minimum period, in accordance with Article 248 of the Revised Penal Code. The Indeterminate Sentence Law was applied, resulting in the modified sentence.
Main Doctrine
The aggravating circumstance of disregard of sex cannot be considered unless it is proved that the accused deliberately intended to offend or insult the sex of the victim. Abuse of superior strength is absorbed by treachery when treachery qualifies the crime as murder. Lack of instruction is not mitigating if the accused has received some education. Obfuscation is not mitigating if the revelation causing it is not sufficient to produce mental blindness.