People v. Crisostomo
REITERATIONFacts
The Antecedents: The accused, Victorino Crisostomo, was charged with the crime of estafa for defrauding the offended party in the amount of P7. Procedural History: The Court of First Instance of Manila found the accused guilty of estafa and imposed a penalty of one month and one day of arresto mayor, with subsidiary imprisonment in case of insolvency, and ordered him to indemnify the offended party in the amount of P7. Additionally, due to being a habitual delinquent, he was sentenced to an additional penalty of six years and one day of prision mayor. The Appeal: The accused appealed the decision of the Court of First Instance. Upon being informed of the complaint, the appellant declared himself guilty.
Issue(s)
Whether the penalty imposed by the trial court for estafa, considering the plea of guilt and the aggravating circumstance of recidivism, is correct. Whether the additional penalty for habitual delinquency was correctly imposed.
Ruling
The Court modified the principal penalty to three months and eleven days of arresto mayor, and affirmed the rest of the appealed sentence, including the additional penalty for habitual delinquency. The sentence was confirmed in all other respects.
Ratio Decidendi
On Issue 1: The Court found that the penalty for estafa, under Article 315(1)(b) of the Revised Penal Code, should be arresto mayor in its medium and maximum periods. Although the accused pleaded guilty, which is an ordinary mitigating circumstance, this was compensated by the aggravating circumstance of recidivism. Therefore, the penalty should be imposed in its medium period, which ranges from three months and eleven days to four months and twenty days of arresto mayor. The trial court's imposition of one month and one day of arresto mayor was thus modified to the medium period. On Issue 2: The Court affirmed the additional penalty imposed for habitual delinquency. The records indicated that this was the appellant's third conviction, which correctly warranted the imposition of the additional penalty for habitual delinquency as provided by law. The trial court's assessment in this regard was deemed correct and was upheld by the Supreme Court.
Main Doctrine
When an accused pleads guilty to estafa, the mitigating circumstance of plea of guilt is compensated by the aggravating circumstance of recidivism, leading to the imposition of the penalty in its medium period. Furthermore, habitual delinquency, based on prior convictions, warrants the imposition of an additional penalty as prescribed by law.