G.R. No. L-2730 - People vs. Aquino

Defendant Ernesto Aquino was indicted in the Court of First Instance of Manila for committing serious physical injuries through reckless imprudence.
The offense was allegedly committed on March 27, 1948, in the City of Manila by driving a civilian jeepney with defective brakes, without a valid driver’s license.
The information charged that while driving "westward along Legarda St.," Aquino drove at a speed deemed "greater than was reasonable and proper" under the circumstances, ultimately hitting Dimas Serrano.

Aquino initially pleaded not guilty upon arraignment on April 19, 1948.
His counsel, noting his status as a student, represented that he should be allowed to finish the present semester before incarceration, causing a postponement of the hearing until January 4, 1949.
On January 4, 1949, Aquino withdrew his plea of not guilty and, after the second reading of the information, entered a plea of guilty.
In court, he admitted to driving the vehicle without a license and acknowledged the factual allegations as contained in the information, including the particulars of the accident.

Based on Aquino’s plea of guilty and the detailed account of the accident—specifically, that his reckless driving caused physical injuries resulting in:

A simple, pertrochanteric fracture of the right femur with varus deformity, and
A lacerated wound at the antero-medial aspect of the left ankle requiring prolonged medical attention—

the trial court sentenced him on January 4, 1949, to one year’s imprisonment, along with the payment of costs.

On the same day, Aquino moved for reconsideration of the judgment, praying for a lighter, indeterminate sentence based on his voluntary plea and alleged mitigating circumstances.
The motion for reconsideration was set for further hearing on January 10, 1949; however, Aquino (or his lawyer) failed to appear, and with the lower court having lost jurisdiction due to his subsequent appeal, the motion was denied.

The trial court erred in not giving due weight to his "sickly condition and appearance" during trial, asserting that such circumstances could have mitigated the severity of the penalty.
The court improperly questioned him regarding the possession of a driver’s license, thereby allegedly compelling him to testify against himself even though he had pleaded guilty.
The sentence imposed was unusually heavy and inconsistent with the generally accepted practice for similar offenses.

Aquino’s brief also contained factual assertions not recorded in the information, which the court dismissed as unreliable since his plea of guilty constituted an acceptance of all allegations in the formal charge.

Whether the trial court erred in not considering Aquino’s allegedly sickly condition and appearance as a mitigating circumstance in the imposition of his sentence.

The defense argued that his physical condition should have factored into a lighter penalty.
The court noted that the plea of guilty dispensed with the need to present evidence or testimony on the matter.

Whether the trial court improperly compelled Aquino to testify against himself by questioning him about his possession of a driver’s license, despite his guilty plea.

The issue centered on the accused’s claim that such questioning forced him to offer self-incriminatory evidence.
The court held that since Aquino answered voluntarily, no violation of his right against self-incrimination occurred.

Whether the sentence imposed by the trial court was disproportionate or excessively severe in comparison to the established penalties for similar offenses under the applicable statute.

Aquino contended that the penalty was unusually heavy, not reflecting customary practice.
The court needed to assess whether the special law (Act No. 3992) mandated a different approach or penalty severity.