Case Digest (G.R. No. 195194)
Facts:
In 1932, Marciano Medina (alias Mariano Medina, alias Alejandro Dola) was charged before the Court of First Instance of Rizal with trespass to dwelling with frustrated homicide and less serious physical injuries. On August 7, 1932, at night in Parañaque, Province of Rizal, Medina forced his way through a window protected by wire screens into the home of Capt. J. H. Davidson. When the occupants discovered him and attempted his arrest, he stabbed Joseph Davidson in the upper left chest with a knife, inflicting a potentially mortal wound later saved by timely medical aid. As he fled, Medina also wounded Capt. Davidson (three stab wounds), Mrs. Davidson (lacerations severing tendons), and their daughter Mary (scalp wound). All victims required medical care for more than ten but fewer than thirty days and were incapacitated for the same period. Medina, represented by court-appointed counsel, pleaded guilty. The trial court found four aggravating circumstances (night time, disregard oCase Digest (G.R. No. 195194)
Facts:
- Commission of the Offenses
- On August 7, 1932, at night in Paranaque, Rizal, Marciano Medina forcibly entered Capt. J.H. Davidson’s dwelling by breaking and passing through a window.
- Upon detection, he assaulted Joseph Davidson with an open knife, inflicting a mortal chest wound that penetrated the lung but was rendered nonfatal by prompt medical aid.
- In his escape, he also wounded:
- The injuries to Captain, Mrs. Davidson, and Mary Davidson required 10 to 30 days of medical attendance and incapacitated them for the same period.
- Aggravating and Mitigating Circumstances
- Aggravating circumstances: night time commission; disregard of sex (two female victims); unlawful entry; breaking of window; four prior convictions for theft and other lesser offenses.
- Mitigating circumstance: plea of guilty.
- Trial and Lower Court Proceedings
- Accused was represented by court-appointed counsel, arraigned, and pleaded “guilty,” then testified in his own behalf.
- The Court of First Instance of Rizal found him guilty of trespass to dwelling with violence, frustrated homicide, and less serious physical injuries.
- Original sentences imposed:
- Appeal
- Appellant’s counsel argued that convicting and sentencing on three crimes was improper and deprived the accused of a fair trial.
- He prayed for remand to allow the fiscal to choose the charge or to file separate informations, and contended that only less serious injuries could be sustained.
Issues:
- Whether an information charging multiple offenses without demurrer is objectionable or deemed waived.
- Whether a plea of guilty, without further evidence, suffices to sustain conviction.
- Whether multiple sentences for distinct offenses may be imposed under the Revised Penal Code.
- Whether failure of counsel to demur prejudiced the appellant’s right to a fair trial.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)