Case Digest (G.R. No. L-14783)
Facts:
The People of the Philippines v. Marcial Ama y Perez, G.R. No. L-14783, April 29, 1961, the Supreme Court En Banc, Per Curiam. The prosecution (plaintiff-appellee) charged Marcial Ama y Perez, Ernesto de Jesus, and Alejandro Ramos with murder before the Court of First Instance of Rizal by an information alleging that on August 27, 1958, at New Bilibid Prison they, conspiring together and armed with sharp-pointed instruments, stabbed Almario Bautista causing his instantaneous death; the information also alleged the aggravating circumstances of quasi-recidivism (per Art. 160, Revised Penal Code) and that the crime was committed in the presence of public authorities.At arraignment Ama initially pleaded not guilty. The trial court set the case for hearing on November 25, 1958; on that date De Jesus and Ramos obtained a postponement to seek reinvestigation, while Ama moved, with the assistance of appointed counsel de oficio, to withdraw his not-guilty plea and to plead guilty — which the court allowed after the information was again read and explained to him. Defense counsel then moved for imposition of the minimum penalty in view of the plea; the prosecution objected, arguing that quasi-recidivism could not be offset by a plea of guilty and thus the death penalty was proper.
The fiscal produced proof regarding the aggravating circumstances alleged. The trial court found the aggravating circumstances established and sentenced Ama to death, ordered indemnity of P6,000 to the heirs, no subsidiary imprisonment, and costs. The case was elevated to the Supreme Court for review pursuant to Section 9, Rule 119 of the Rules of Court. Appellant's principal assignments of error were that (1) the trial court should have informed him that his guilty plea could not negate the aggravating circu...(Subscriber-Only)
Issues:
- Did the trial court err in allowing appellant to change his plea to guilty without informing him that his plea could not offset the aggravating circumstance of quasi-recidivism alleged in the information?
- Can a conviction — including a capital conviction — be sustained on a plea of guilty alone without requiring the prosecution to p...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)