Case Digest (G.R. No. L-55309)
Case Digest (G.R. No. L-55309)
Facts:
The People of the Philippines v. Alberto Abrea y Arancon, G.R. No. L-55309, February 22, 1982, the Supreme Court En Banc, Abad Santos, J., writing for the Court.The prosecution, the People, charged Alberto Abrea y Arancon (appellant) by amended information with murder committed on August 20, 1980, inside the Zamboanga del Norte Provincial Jail at Sicayab, Dipolog City. The information alleged the killing was attended by treachery and evident premeditation and that appellant was a quasi-recidivist, previously convicted of robbery with homicide and sentenced to reclusion perpetua. The information also claimed civil damages for the heirs of the victim, Anatalio Coca.
At arraignment on September 2, 1980, appellant pleaded guilty. The trial court conducted the cautionary inquiry required in capital cases and, on September 4, 1980, called upon the prosecution to present evidence to substantiate the information despite the plea. Prosecution witnesses included detention prisoner Warlito Caibang (an eyewitness), Officer-in-Charge Sofronio Peras, clerk Felizardo Acaylar, and Dr. Luis P. Young (medical witness). The testimony established that Coca was stabbed once in the left back while receiving his corn grits ration and died soon after; the stab was from behind and unexpected.
The defense presented inmate Quintero and the appellant, who testified that prior confrontations occurred that day and that Coca had earlier brandished a knife and struck at appellant’s cell; appellant said he followed Coca shortly thereafter and stabbed him but claimed there was little time to premeditate. The trial court found appellant guilty of murder qualified by treachery and evident premeditation, with the special aggravating circumstance of quasi-recidivism, and sentenced him to death. The trial judge also recommended executive clemency by commutation to life imprisonment.
Because a death sentence was imposed, the case reached the Supreme Court by automatic review. Counsel de oficio (Atty. Ramon A. Gonzales filed a brief; Atty. Orlando O. Barrera had assisted at arraignment) admitted the factual statements of the trial court. The Solicitor General contended that the guilty plea admitted the qualifying circumstances and that evident premeditation was established; defense argued absence of evident premeditation and urged mitigation. The Supreme Court reviewed the entire record under the automatic-review function and considered whether the death penalty was proper in light of the facts and appellant’s quasi-recidivism.
Issues:
- Does a plea of guilty prevent the Supreme Court, on automatic review in a capital case, from examining the record to determine the existence of qualifying or aggravating circumstances alleged in the information?
- Was there evident premeditation in the killing of Anatalio Coca?
- If evident premeditation is absent, does appellant’s status as a quasi-recidivist nonetheless mandate the imposition of the death penalty under the Revised Penal Code?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)