G.R. No. L-51368 - People vs. Macatanda

On the evening of December 25, 1976, the complainant left his two carabaos near his house in Salug, Sapad, Lanao del Norte.
The following morning, the complainant discovered that the carabaos were missing and immediately reported the loss to a local constabulary officer, Welfredo Bucol, the team leader of the home defense unit.
The complainant joined a posse—including members of the constabulary and the barangay captain—to search for the missing carabaos.
At Pawak, Salvador, Lanao del Norte, the posse encountered four individuals, namely Macabaas, Mangigya, Makaonggos, and the appellant, Saglala Macatanda, in possession of the two carabaos.
Upon being discovered, the group engaged the posse in a gun battle during which the appellant was wounded; his companions fled, leaving him behind with the carabaos.

Appellant Saglala Macatanda was charged with cattle rustling under Presidential Decree No. 533 and pleaded guilty before the Court of First Instance of Lanao del Norte, Branch IV in Iligan City.
The trial court convicted him beyond reasonable doubt and imposed an indeterminate sentence: a minimum of six (6) years and one (1) day of prision mayor and a maximum of eight (8) years of prision mayor.
The period of his preventive imprisonment was credited in his favor pursuant to Article 29 of the Revised Penal Code.
The court ordered a payment of One Hundred Fifty Pesos to Atty. Reynaldo Echavez for counsel de oficio services, with costs imposed on the appellant.

On appeal, Saglala Macatanda raised two key legal questions regarding mitigation:

Whether his lack of instruction (i.e., ignorance or limited education) should be considered a mitigating circumstance.
Whether his status as a member of a cultural minority, being a Moslem, should also be taken into account for mitigation.

The appellant argued that these circumstances, taken jointly, warranted a reduction of the penalty imposed by the trial court.
He drew support from the U.S. vs. Maqui case, which had considered the lack of instruction as a mitigating factor in theft-related offenses.
The trial court, however, only credited the mitigating circumstances of a plea of guilty and extreme poverty, explicitly omitting his claims based on his lack of instruction and his cultural minority status.

Appellant contended that, similar to the Maqui case, his lack of instruction and cultural background should automatically afford him a more lenient sentence even in an offense under a special law such as PD No. 533.
It was argued that the prosecution did not object to the application of these mitigating circumstances.
The defense maintained that these factors should allow the lower court to lower the penalty by one degree under Article 64, paragraph 5 of the Revised Penal Code.
However, the record revealed that, due to his plea of guilty, no evidence was presented to substantiate the claim of lack of instruction.
Additionally, the jurisprudence indicated that membership in a cultural minority does not inherently imply an uncivilized or semi-uncivilized state that would merit mitigation.

Whether the mitigating circumstances of lack of instruction and being a member of a cultural minority (Moslem) can be applied to mitigate the appellant’s criminal liability under PD No. 533 for cattle rustling.
Whether the trial court erred in not considering these alleged mitigating circumstances when imposing the penalty.
Whether the trial court’s computation of the penalty, specifically the reduction by one degree in light of the mitigating circumstances of plea of guilty and extreme poverty, was correct, especially in light of the appellant’s argument for applying Article 64 of the Revised Penal Code.