People v. Lacsamana
REITERATIONFacts
The Antecedents: Ruperto Gregorio and Joaquin Llanera, along with Pastor Lacsamana, Joaquin Reyes, and Florentina de la Cruz, were accused of robbery. The charge alleged that on August 4, 1939, they unlawfully took personal property valued at P52 from Tomas Poy Lorenzo's house in Angeles, Pampanga, by breaking down the door. Procedural History: The trial court convicted Ruperto Gregorio to five years of prision correccional plus ten years and one day of prision mayor, and Joaquin Llanera to three years and six months of prision correccional. Both were ordered to jointly and severally indemnify Tomas Poy Lorenzo in the amount of P52 and pay proportionate costs. Both appealed the sentence. The Petition: The appellants, Ruperto Gregorio and Joaquin Llanera, pleaded guilty to the crime of robbery. Their defense counsel did not dispute the facts constituting the offense. The defense argued that the aggravating circumstances of nocturnity and use of a motor vehicle should not be considered against the appellants. Ruperto Gregorio also contended that he was not a habitual delinquent as defined by Article 62, Section 5(c) of the Revised Penal Code, due to the time elapsed since his last conviction. He further argued that he could not be declared a habitual delinquent because he committed no offense during the ten years prior to his last release and had been sentenced to an additional fifteen years for being a habitual delinquent in a previous case.
Issue(s)
Whether the aggravating circumstances of nocturnity and use of a motor vehicle should be considered against the appellants despite their voluntary plea of guilt. Whether Ruperto Gregorio qualifies as a habitual delinquent under Article 62, Section 5(c) of the Revised Penal Code. Whether the penalty imposed on Joaquin Llanera should be indeterminate under the Indeterminate Sentence Law.
Ruling
The Supreme Court modified the decision of the trial court. It found the appellants guilty of robbery in an uninhabited house. Ruperto Gregorio was sentenced to one year, eight months, and one day of prision correccional, plus an additional twelve years of prision mayor. Joaquin Llanera was sentenced to an indeterminate penalty of four months of arresto mayor to one year, eight months, and one day of prision correccional. Both were ordered to jointly and severally indemnify Tomas Poy Lorenzo in the amount of P52 and pay the proportionate costs of both instances. In case of insolvency for the indemnity, Joaquin Llanera would suffer subsidiary imprisonment.
Ratio Decidendi
On the issue of aggravating circumstances: The Court held that the voluntary plea of guilt by the appellants admitted all material allegations in the complaint, including the aggravating circumstances of nocturnity and use of a motor vehicle. The defense's attempt to exclude these circumstances based on evidence presented in the trial of their co-accused was deemed unsustainable, as such evidence could not be considered in determining the responsibility of the appellants or the penalty imposed upon them. The Court emphasized that by pleading guilty, the appellants implicitly admitted the presence of these circumstances as alleged in the complaint. On the issue of habitual delinquency for Ruperto Gregorio: The Court found Ruperto Gregorio to be a habitual delinquent. The Court clarified that the last paragraph of Article 62 of the Revised Penal Code defines a habitual delinquent as a person who, within ten years from the date of release or last conviction for robbery, theft, estafa, or falsification, has been found guilty of any of these offenses for the third or more times. Gregorio's prior convictions, including five for theft and one for robbery, placed him within this definition. The Court rejected his argument that his last conviction in 1927, more than ten years prior to the offense in 1939, excluded him, stating that the ten-year period is from the date of release or last conviction. Furthermore, the Court dismissed his claim that he could not be a habitual delinquent because he committed no offense in the ten years prior to his last release and had been sentenced to an additional fifteen years previously. The law does not exempt an offender from habitual delinquency or the additional penalty under such conditions; it is sufficient that he be found guilty of the specified offenses for the third or more times, and that his last conviction or release occurred within ten years immediately preceding the offense charged. On the penalty for Joaquin Llanera: The Court determined that the crime committed was robbery in an uninhabited house, punishable under the penultimate paragraph of Article 302 of the Revised Penal Code, as amended by Commonwealth Act No. 417, with arresto mayor in its maximum period to prision correccional in its minimum period, given the value of P52 stolen. Considering the aggravating circumstances of nocturnity and use of a motor vehicle, and that one of these should be compensated by the mitigating circumstance of a plea of guilt, the Court imposed the maximum degree of the composite penalty. For Joaquin Llanera, who was not a habitual delinquent, the Court applied the Indeterminate Sentence Law (Commonwealth Act No. 4103, as amended by Commonwealth Act No. 4225), imposing an indeterminate penalty of four months of arresto mayor to one year, eight months, and one day of prision correccional.
Main Doctrine
The voluntary plea of guilty admits all material allegations in the complaint, including habitual delinquency and aggravating circumstances, unless specifically denied or disproven. The penalty for robbery in an uninhabited house is determined by the value of the stolen property, with aggravating circumstances of nocturnity and use of a motor vehicle to be considered. Habitual delinquency and its corresponding additional penalty apply based on prior convictions within the ten-year period preceding the commission of the offense, regardless of the time elapsed between prior convictions or the imposition of additional penalties in previous cases. The Indeterminate Sentence Law applies to offenders who are not habitual delinquents.