G.R. No. 7540 - People vs Mendoza

The case involves the automatic review of the death sentence imposed on appellant Rodolfo Andaya by the Court of First Instance of Davao.
This is the second imposition of the death penalty on Andaya, after the initial sentence was set aside due to an improvident plea of guilty.
Upon remand, the trial court conducted a proper hearing in accordance with the Court’s earlier directive and allowed the prosecution to present its evidence.

Initially, Andaya entered a conditional plea of guilty with a request “to be sentenced only to life imprisonment,” which was directed by the trial court to be recorded as a plea of not guilty.
Upon re-arraignment on August 3, 1977, and after being apprised of the grave consequences, Andaya changed his plea to an unqualified plea of guilty.
The accused, despite his earlier conditional plea, maintained his unqualified plea even after full explanation of its legal repercussions, including the inevitability of the death penalty in light of the aggravating circumstances.

Judge Sabas Sayon, who detailed the investigation, the accused’s extra-judicial confessions, and the circumstances under which the affidavits were executed.
Sgt. Felix Luego, who provided testimony on identifying Andaya as the killer and on the sequence of reports and inquest regarding the crime.
Deputy Chief of Police Bernabe Dujali, who confirmed the investigation process, the confession given by Andaya, and the fact that the accused fully understood the affidavit’s contents in his native dialect.
Andres Perez, an employee at the Davao Penal Colony, who substantiated the accused’s identity through prior imprisonment records and attested to his behavior before the commission of the crime.

The evidence included the accused’s own statements in affidavits (notably Exhibits D and E), which detailed the execution of the crime as well as circumstantial evidence relating to the handling and recording of his confession.

Andaya was charged with murder, with the evidence supporting the finding that the killing involved aggravating circumstances such as treachery, abuse of superior strength, evident premeditation, and quasi-recidivism.
The coalitions of evidence indicated that the killing was not motivated by a robbery, even though the defense sought to reclassify the offense as “attempted robbery with homicide” under Article 297 of the Revised Penal Code.

Counsel de oficio, Atty. Ponciano Mortera, argued that the offense should be adjudged as attempted robbery with homicide, which would allow for the imposition of reclusion perpetua rather than the death penalty.
The argument was partly based on the testimony from Andaya’s preliminary statement suggesting an intent to rob the victim, Paulino Malbas.
However, upon cross-examination and further evidentiary presentation, it was clarified that the killing was motivated by personal reasons (specifically a retaliatory motive regarding the victim’s interference with a personal matter involving a fighting cock) rather than the intent to commit robbery.

The prosecution’s evidence, particularly the clear and sustained admissions of Andaya during the inquests and in open court, reinforced the classification of the crime as murder.
Despite the presence of mitigating circumstances (voluntary surrender, intoxication, exemplary conduct and industry while in confinement), these were insufficient to counterbalance the gravity of the aggravating factors—specifically, quasi-recidivism and the nature of the killing.
The case also featured concurring and separate opinions:

Justice Teehankee voted for the imposition of reclusion perpetua, citing the mitigating circumstances and the rehabilitation prospects of the accused.
Justice Aquino, while concurring with the imposition of the death penalty on the facts, dissented on the recommendation for executive clemency to commute the penalty.
Other members of the Court concurred, ultimately leading to the ruling that although there was insufficient vote for the death penalty, the sentence was affirmed as reclusion perpetua.

Whether the killing committed by Andaya should be considered murder or re-categorized under Article 297 as attempted robbery with homicide.
Determining if the evidence supports the presence of aggravating circumstances that elevate a homicide to murder.

Whether the unqualified plea of guilty entered by Andaya—after being fully apprised of the consequences—was valid and informed.
The legal effect of having changed from a conditional plea to an unqualified plea on the subsequent imposition of the penalty.

Whether the mitigating factors presented (voluntary surrender, intoxication, exemplary conduct, and industry) were sufficient to lower the penalty from death to reclusion perpetua.
The challenge of balancing mitigating circumstances against aggravating facts such as quasi-recidivism.

Whether Article 297 of the Revised Penal Code is applicable in a case where robbery was not actually committed, despite allegations of an attempted robbery.
Interpreting the scope of “homicide” in Article 297, particularly when it encompasses murder when committed under certain circumstances.