People v. Fernandez
REITERATIONFacts
The Antecedents: The accused, Dionisio Fernandez y Tabuso, was charged with frustrated murder for attacking Martin Librera on May 10, 1939, in Manila. The information alleged that the accused, with intent to kill, evident premeditation, and treachery, beat the victim with a piece of wood and stabbed him with a fan-knife while the victim was sleeping. The victim sustained severe physical injuries, including stab wounds to the axilla and lung, lacerated wounds on the head, and hemothorax, which were mortal or dangerous to life. The death of the victim was prevented only by timely and able medical assistance. Procedural History: The accused pleaded guilty to the charges. The trial court convicted him and imposed a penalty of six years and one day of prision mayor, as a minimum, to twelve years and one day of reclusion temporal, as a maximum. This penalty was imposed in the medium period, as provided by Article 250 in relation to Article 248 of the Revised Penal Code. The Appeal: The accused appealed the decision, arguing that the penalty should have been imposed in its minimum period due to the mitigating circumstance of his plea of guilty. The defense contended that this mitigating circumstance should have been given full effect. The prosecution, however, maintained that the aggravating circumstances of treachery and evident premeditation, as alleged in the information, offset the mitigating circumstance of the plea of guilty, justifying the imposition of the penalty in the medium period.
Issue(s)
Whether the mitigating circumstance of a plea of guilty should result in the imposition of the penalty in its minimum period, despite the presence of aggravating circumstances of treachery and evident premeditation. Whether the penalty imposed by the trial court, which was in the medium period, is correct given the facts and the law.
Ruling
The Supreme Court affirmed the appealed decision. The penalty imposed by the trial court in the medium period was upheld, with costs assessed against the appellant.
Ratio Decidendi
On Issue 1: The Court held that while a plea of guilty is a mitigating circumstance, it does not automatically warrant the imposition of the penalty in its minimum period. The information alleged that the accused acted with evident premeditation and treachery, which are considered aggravating circumstances. The presence of these aggravating circumstances can offset the mitigating effect of a plea of guilty. Therefore, the mitigating circumstance of the plea of guilty does not stand alone and must be considered in conjunction with the aggravating circumstances alleged. On Issue 2: The Court found that the trial court correctly imposed the penalty in its medium period. The Revised Penal Code provides penalties for frustrated murder. Article 248 defines murder, and Article 250 deals with the penalties for frustrated crimes. The penalty for murder is reclusion temporal in its maximum period to death. For frustrated murder, the penalty is one degree lower, which is reclusion temporal in its medium period. The information explicitly alleged treachery and evident premeditation, which are qualifying and generic aggravating circumstances, respectively. These circumstances, when present, call for the imposition of the penalty in its medium period, especially when they offset a mitigating circumstance like a plea of guilty. The trial court's imposition of the penalty in the medium period was thus in accordance with the law and the facts presented.
Main Doctrine
When a plea of guilty is entered, it is considered a mitigating circumstance. However, this mitigating circumstance can be offset by the presence of aggravating circumstances, such as treachery and evident premeditation, which were alleged in the information. In such a scenario, the penalty should be imposed in its medium period, as the aggravating circumstances counterbalance the mitigating effect of the plea.