People v. Guzman
REITERATIONFacts
The Antecedents: On February 17, 1939, an information for qualified theft with habitual delinquency under Article 62 of the Revised Penal Code was filed against Pedro de Guzman. The accused pleaded guilty to the information. Procedural History: The Court of First Instance of Manila found the defendant guilty as charged and sentenced him to two (2) years, four (4) months and one (1) day of prision correccional, an additional penalty of ten (10) years and one (1) day for habitual delinquency, to indemnify the offended party in the amount of P121, and to pay costs. The Petition: The defendant appealed the decision. His counsel de oficio recommended affirmance, while the Assistant Solicitor-General recommended an increase in the principal penalty.
Issue(s)
Whether a plea of guilty constitutes an admission of the fact of habitual delinquency as alleged in the information. Whether the trial court correctly calculated and imposed the penalty for qualified theft based on the value of the stolen property and the presence of recidivism and a plea of guilty.
Ruling
The Court affirmed the judgment of the lower court in all other respects but increased the principal penalty. The defendant-appellant was sentenced to four (4) years, two (2) months and one (1) day of prision correccional, plus the additional penalty of ten (10) years and one (1) day for habitual delinquency, to indemnify the offended party in the amount of P121, and to pay the costs.
Ratio Decidendi
On Issue 1: The Court ruled that a plea of guilty is a formal admission of all material facts alleged in the information. Citing United States v. Barba, the Court held that when an information alleges prior convictions to establish habitual delinquency, a plea of guilty admits those prior convictions just as it admits the facts of the current crime. The essence of the plea is that the accused admits guilt with full knowledge of the consequences, supplying the proof necessary to sustain a conviction without further evidence from the prosecution. Therefore, because De Guzman pleaded guilty to an information alleging his seventh conviction, the trial court was correct in finding him a habitual delinquent and imposing the additional penalty under Article 62 of the Revised Penal Code (RPC). On Issue 2: The Court found that the trial court's principal penalty was below the range prescribed by law. Under Article 310 of the Revised Penal Code (RPC), the penalty for qualified theft is two degrees higher than that provided for simple theft in Article 309. For property valued at P121, Article 309, paragraph 4, prescribes arresto mayor in its medium period to prision correccional in its minimum period. Two degrees higher results in a range from prision correccional in its medium period to prision mayor in its minimum period. Although the plea of guilty (mitigating) and recidivism (aggravating) offset each other, the penalty must be imposed in the medium period of the higher range, which is four years, two months, and one day to six years. Since the trial court only imposed two years, four months, and one day, the Supreme Court increased the penalty to four years, two months, and one day of prision correccional to comply with the Revised Penal Code (RPC).
Main Doctrine
A plea of guilty to an information charging not only a crime but also prior convictions admits the facts constituting the crime and the prior convictions, and is sufficient to sustain a conviction without further evidence. The penalty imposed must be in accordance with law, considering the admitted facts and any attendant circumstances, including habitual delinquency.