G.R. No. L-32623 - People vs. Ferdez

The People of the Philippines brought the case against Enrique Fernandez and his co-accused—Dario Sitoy, Clemente Reposala, and Vencio Almonte—for the crime of “Robbery with Frustrated Homicide and Multiple Homicide.”
The trial court in Zamboanga del Sur handled the case where the defendant, Enrique Fernandez, entered a plea of guilty after being duly informed of the seriousness of the charge and the imposition of the corresponding penalty.

On or about January 4, 1970, at approximately 10:00 p.m., at Barrio La Suerte, City of Pagadian, the accused, acting in concert, allegedly committed the offense.
The criminal act involved a planned and deliberate robbery involving the taking and carrying away of cash amounting to P350.00 from one Sebastian Espelita, Sr.

The accused used force and violence to rob Sebastian Espelita, Sr., and, with an intent to kill, attacked Sebastian Espelita, Jr., using hunting knives which resulted in a severe chest wound.
In further actions during the commission of the crime, the accused, with the intent to kill, assaulted and inflicted fatal wounds on additional victims including Sebastian Espelita, Sr., Dolores Espelita, George Espelita, and Alejandra Espelita.
Notably, Dolores Espelita was reported to have been pregnant with a five-month-old baby, a fact that further underscored the gravity of the incident.
The information made mention that the crime was committed "in the darkness of the night," a detail later examined for its potential aggravating effect.

Upon arraignment, Enrique Fernandez pleaded guilty; the plea was treated as a mitigating circumstance during sentencing.
The trial court rendered a judgment sentencing the accused to the extreme penalty of death for the charged crimes, and further ordered indemnification to the heirs of the victims amounting to P12,000.00 as well as the payment of court costs.
The cases against the other co-accused were set for trial, with the focus on the penalty imposed against Fernandez.

Counsel de oficio raised the concern regarding whether the trial court properly considered the mitigating circumstance of the plea of guilty in relation to the stipulated imposition of the death penalty.
A central contention was the validity of treating the mere fact that the crime was committed “in the darkness of the night” as an aggravating circumstance, particularly whether it satisfied the legal requirement of facilitating the commission of the offense.

Whether the mitigating circumstance of the plea of guilty should offset or diminish the penalty imposed, especially given the absence of any well-established aggravating factors.
Whether the mere statement that the crime was committed in the darkness of the night qualifies as an aggravating circumstance under Article 14(6) of the Revised Penal Code.
Whether the extreme penalty of death imposed by the lower court is appropriate considering the mitigating circumstance provided by the defendant’s plea and the failure to establish any aggravating circumstance that meets the legal threshold.