Case Digest (G.R. No. L-34754)
Facts:
The People of the Philippines v. Silvestre Mate y Abad, G.R. No. L-34754, March 27, 1981, Supreme Court En Banc, Per Curiam, involves the conviction of Silvestre Mate for kidnapping for ransom with murder and frustrated murder.An information was filed on November 16, 1971 in the Circuit Criminal Court of Rizal charging Silvestre Mate y Abad (and three John/Peter/Henry Does) with Kidnapping for Ransom with Murder and Frustrated Murder (Art. 267, Revised Penal Code) arising from events at the Butler residence in Forbes Park, Makati on October 31–November 1, 1971. At arraignment on November 20, 1971, Mate, after being informed of his rights and the possible penalty, entered a plea of guilty. The trial court immediately pronounced judgment of conviction and sentenced Mate to death, ordered indemnities and damages, and then proceeded to receive the prosecution’s evidence at subsequent hearings.
The prosecution’s evidence, adduced after the judgment pronouncement, included testimony from police and investigators, an autopsy report (Exhibit G), and documentary evidence. The facts established that Mate and an accomplice entered the Butler compound hidden in the guesthouse; Martina Caldoza, a maid, was assaulted, repeatedly stabbed and killed; Mrs. Caroline Butler was shot and survived due to timely medical treatment; and the child Suzie (Susan) Butler was held for ransom and released after P15,000 was paid in Botolan, Zambales. Mate was later arrested in Sitio Paitan on November 2, 1971, with money (P13,553 recovered) and a shotgun. He executed extrajudicial statements (Exhibits A, B, J) and later testified against co-accused Albino Bohol, affirming the same narrations.
Mate’s defense raised two principal objections: (1) the trial court erred in rendering judgment immediately after his guilty plea and before the reception of evidence, and (2) the prosecutor failed to formally offer his exhibits despite their marking and identification. The trial court nevertheless received evide...(Pro-only)
Issues:
- Did the trial court’s pronouncement of judgment immediately after the accused’s plea of guilty—prior to receiving the prosecution’s evidence—warrant reversal of the conviction?
- Were the accused’s extrajudicial statements (Exhibits A, B, and J) admissible against him?
- Was the conviction supported by sufficient evidence to uphold gu...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)