G.R. No. 45704 - People vs. Mangsant y Esmi

On April 7, 1937, in the City of Manila, the defendant, Clemente Mangsant y Esmina, allegedly attacked Demetria Ferrer, a 14-year-old girl, with evident premeditation.
The information prosecuted that the defendant, motivated by passion and jealousy—stemming from the discovery that his fiancée loved another man—stabbed the victim from behind with a knife, inflicting multiple wounds which resulted in her instantaneous death.
The facts as alleged emphasized aggravating circumstances such as evident premeditation, disregard of sex, abuse of superior strength, and treachery, which, according to the information, qualified the crime as murder under Article 248 of the Revised Penal Code.

On arraignment, the defendant initially pleaded “not guilty,” but subsequently changed his plea to “guilty” before the prosecution presented its evidence.
The defendant was allowed to testify under oath, in which he admitted that he and the deceased were lovers who had planned to marry in the following May.
He claimed that upon visiting his fiancée on the day of the incident and learning about her affection for another man, he acted under an uncontrollable impulse, resulting in her fatal stabbing.

The Court of First Instance of Manila found the defendant guilty, noting that despite the mitigating circumstances of lack of instruction, obfuscation, and plea of guilty, the aggravating circumstances—particularly treachery—were sufficient and offset these mitigating factors.
The judgment imposed reclusion perpetua (life imprisonment) or its equivalent measure under Article 248, the indemnification of the heirs of the deceased to the extent of one thousand pesos (₱1,000), and the payment of costs.

The attorney de oficio for the defendant recommended affirming the lower court’s decision, stating that the judgment was in accordance with law.
The Solicitor-General, however, argued that, save for treachery (as a qualifying circumstance) and the mitigating circumstance of voluntary confession, the other aggravating and mitigating circumstances were neither proved nor admitted by the defendant.
The Solicitor-General maintained that since the defendant was allowed to explain the circumstances, he essentially negated the alleged aggravating circumstances, and the mitigating circumstances could not be inferred solely from his explanation.

Whether the aggravating circumstances of evident premeditation, disregard of sex, and abuse of superior strength, as alleged in the information, were sufficiently proven or admitted by the defendant.

The court had to determine if the evidence supported the allegation of premeditation or if it was merely an imputation by the prosecution.
It was questioned whether the act of stabbing the victim, given the circumstances, inherently justified invoking the aggravating circumstances in addition to the qualifying circumstance of treachery.

Whether the mitigating circumstances alleged, such as lack of instruction and the effect of obfuscation resulting from the defendant’s emotional state or the impulse occasioned by jealousy, were applicable in reducing the sentence.

The issue extended to the propriety of considering “lack of instruction” when the defendant had attended a public elementary school, albeit for only a first-grade level.
The effect of voluntary confession, as an independent mitigating circumstance, had to be assessed in the context of its impact on the final sentence.

The proper application of the principles relating to the merging of inherent circumstances (such as abuse of superior strength) into qualified aggravating circumstances like treachery, and whether additional evidence or admission was necessary to invoke them separately.