People v. Quijano
REITERATIONFacts
The Antecedents: The appellant, Calixto Quijano y Pascual, was charged with robbery for an incident on May 17, 1941. The prosecution alleged that Quijano, along with two unknown accomplices, used physical violence, specifically fist blows to the face of Efrain Fajardo, a paymaster, to steal a bag containing two mangoes. The value of the bag was P1.00 and the mangoes P0.05. The information also stated that Quijano was a recidivist, having been previously convicted twice for theft. Procedural History: Quijano initially pleaded not guilty to the charge. During the trial, after the first prosecution witness had testified, he changed his plea to guilty. The Court of First Instance of Manila found him guilty, considering his voluntary confession as a mitigating circumstance, but offset by the aggravating circumstance of recidivism. He was sentenced to an indeterminate penalty of three months of arresto mayor to three years, eight months, and one day of prision correccional, with accessory penalties, indemnity, subsidiary imprisonment, and costs. He appealed this sentence. The Petition: The appellant's counsel de oficio recommended affirming the sentence. However, the Solicitor-General contended that the trial court erred in appreciating the plea of guilty as a mitigating circumstance because it was made after the presentation of some prosecution evidence. The Solicitor-General argued that the penalty should be increased accordingly. The Supreme Court agreed, holding that a confession made after the presentation of evidence cannot be a mitigating circumstance and that the insignificance of the stolen property does not mitigate the crime. Consequently, the penalty was modified to an indeterminate penalty of not less than four months and one day of arresto mayor and not more than six years, ten months, and one day of prision mayor, with the judgment otherwise affirmed.
Issue(s)
Whether the voluntary confession of guilt made after the presentation of part of the prosecution's evidence can be appreciated as a mitigating circumstance. Whether the relative insignificance of the value of the property stolen mitigates the criminality of the robber.
Ruling
The Supreme Court modified the sentence. The Court held that the voluntary confession of guilt was not a mitigating circumstance because it was made after the presentation of part of the prosecution's evidence. The Court also held that the insignificance of the value of the property stolen does not mitigate the criminality of the robber. Consequently, the aggravating circumstance of recidivism was not compensated by any mitigating circumstance, and the penalty should be applied in the maximum degree.
Ratio Decidendi
On the issue of voluntary confession of guilt as a mitigating circumstance: The Court reiterated the principle that for a voluntary confession of guilt to be considered a mitigating circumstance under paragraph 7 of Article 13 of the Revised Penal Code, it must be made prior to the presentation of the evidence for the prosecution. The Court cited previous rulings establishing that a voluntary confession made after part of the prosecution's evidence has been presented cannot be appreciated as a mitigating circumstance. The Court reasoned that an admission of guilt withheld until after the accused has speculated on the proofs against him and satisfied himself that he has no probable escape should not be granted mitigation. The trial court's recognition that the accused was no longer entitled to this mitigating circumstance but nevertheless gave him the benefit thereof due to the insignificant value of the property stolen was deemed an error that could not be sanctioned. On the issue of the insignificance of the value of the property stolen: The Court unequivocally stated that the relative insignificance of the booty does not mitigate the criminality of the robber. On the contrary, the Court reasoned that it serves to bring out the robber's perversity in bolder relief, as one who commits violence against persons for a trifle must be considered a real criminal. This principle underscores that the gravity of the offense is not solely determined by the value of the stolen property but also by the commission of violence and the intent to gain, irrespective of the amount.
Main Doctrine
A voluntary confession of guilt, to be considered a mitigating circumstance under Article 13(7) of the Revised Penal Code, must be made prior to the presentation of evidence for the prosecution. A confession made after part of the prosecution's evidence has been presented cannot be appreciated as a mitigating circumstance. The relative insignificance of the value of the property stolen does not mitigate the criminality of the robber.