Case Digest (G.R. No. 139940) Core Legal Reasoning Model
Facts:
The case in question is "The People of the Philippines vs. Melchor Intal y David," G.R. No. L-10585, decided on April 29, 1957. The appellant, Melchor Intal, was put on trial for double murder. During the proceedings, after the prosecution rested its case and the defense had presented three witnesses, Intal expressed a desire to plead guilty to the lesser charge of double homicide. The prosecution did not object to this motion. Consequently, Intal sought to withdraw his initial plea of not guilty, which the trial court granted, along with the prosecution's request to amend the information to reflect the new plea. Following the amendment, Intal was arraigned again and pleaded guilty to double homicide. His defense counsel highlighted the mitigating circumstance of physical infirmity, which the prosecution acknowledged as well. The trial court sentenced Intal to an indeterminate penalty ranging from 10 years and 1 day of prision mayor to 17 years, 4 months, and 1 da
Case Digest (G.R. No. 139940) Expanded Legal Reasoning Model
Facts:
- Background of the Case
- The defendant, Melchor Intal y David, was originally on trial for double murder.
- During the trial, after the prosecution rested its case and following the presentation of three defense witnesses, the accused expressed his willingness to change his plea from not guilty to guilty for a lesser offense—double homicide.
- Plea and Amendment of Information
- The accused moved to withdraw his previous plea of not guilty and to substitute it with a plea of guilty to the lesser crime of double homicide.
- The prosecution, represented by Assistant Fiscal Carlos Gulman Cruz and private prosecutor Atty. Alfonso Felix, Jr., did not object and even supported the move by requesting an amendment of the information from double murder to double homicide.
- The trial court granted both motions, and the fiscal duly amended the information against the accused.
- Mitigating Circumstances Presented
- When arraigned on the amended information, the accused voluntarily pleaded guilty to double homicide.
- Simultaneously, the accused sought to present the mitigating circumstance of physical infirmity.
- The prosecution acknowledged the existence of this mitigating circumstance, and no aggravating circumstances were alleged in the amended information.
- Trial Court’s Sentence
- Despite the mitigating circumstances, the trial court sentenced the accused to an indeterminate penalty ranging from a minimum of 10 years and 1 day of prision mayor to a maximum of 17 years, 4 months, and 1 day of reclusion temporal, in addition to indemnity and costs.
- The case was then certified by the Court of Appeals solely to review the penalty imposed.
Issues:
- Whether the defendant’s actual plea of guilty to the lesser offense of double homicide should be considered as a mitigating (extenuating) circumstance.
- The issue revolves around the distinction between merely offering to plead guilty to a lesser offense and actually entering such a plea.
- Determining the impact of this mitigating circumstance on the calculation of the penalty.
- Whether the penalty imposed by the trial court adhered to the principles of the Indeterminate Sentence Law given the presence of mitigating and absence of aggravating circumstances.
- Consideration of the appropriate sentence modification when two mitigating circumstances are present.
- The judicial proper application of the precedent set in People vs. Calma regarding the plea to a lesser offense.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)