People v. Yco
REITERATIONFacts
The Antecedents: Lamberto Yco y Guevarra (alias Lamberto Ico) was charged with robbery in an inhabited house before the Court of First Instance of Manila. Procedural History: Despite entering a plea of guilty, the trial court found the appellant guilty of robbery in an uninhabited house and imposed a sentence. The appellant appealed this judgment to the Supreme Court. The Appeal: The appellant contended that the trial court erred in finding him guilty of robbery in an uninhabited house, notwithstanding his unqualified plea of guilty to the charge of robbery in an inhabited house as stated in the information.
Issue(s)
Whether the trial court erred in finding the accused guilty of robbery in an uninhabited house when he pleaded guilty to robbery in an inhabited house as charged in the information.
Ruling
The Supreme Court modified the judgment of the lower court. It held the appellant guilty of robbery in an inhabited house, as originally charged, and sentenced him to an indeterminate penalty of four months of arresto mayor to two years and four months of prision correccional, with accessory penalties, to indemnify the offended party, Sancho Tolentino, in the sum of P92, and to pay the costs.
Ratio Decidendi
On Issue 1: The Supreme Court held that the trial court erred in finding the appellant guilty of robbery in an uninhabited house. The information explicitly charged the appellant with robbery in an inhabited house, and by entering a plea of guilty, the appellant unqualifiedly admitted all the facts alleged in the information. This admission binds the accused to the offense as charged. The lower court's duty was to render judgment based on the offense charged and admitted. Therefore, the court could not deviate from the charge and convict the appellant of a lesser offense not covered by the information, even if the evidence presented might have supported such a conviction. The judgment was modified to reflect the offense admitted by the plea of guilty.
Main Doctrine
When an accused pleads guilty to the charge as stated in the information, such plea is an unqualified admission of the facts alleged. Consequently, the court is bound to convict the accused based on the offense charged and cannot find them guilty of a different offense, even if the evidence might suggest otherwise, unless the information itself is amended.