Case Digest (G.R. No. L-30343)
Facts:
People of the Philippines v. Severo Mengote and Jose Pajares, G.R. No. L-30343, July 25, 1975, Supreme Court En Banc, Martin, J., writing for the Court.On December 6, 1968, an information was filed charging that several persons, including Severo Mengote and Jose Pajares, attacked and killed Francisco Lambino and carried away a pig; the offense was framed as robbery with homicide. At the arraignment on February 25, 1969 in the Court of First Instance of Northern Samar (presided over by Judge Ignacio Mangosing), both accused, represented by Atty. Manuel Hechanova as counsel de oficio, pleaded guilty. The stenographic notes show the information was read, the accused pleaded guilty after being "warned of the consequences," and counsel asked the court to consider mitigating circumstances (voluntary surrender, lack of instruction due to illiteracy) and to credit prior detention; the fiscal admitted voluntary surrender and lack of instruction but objected to crediting detention for robbery with homicide.
Three days later, on February 28, 1969, the trial court rendered judgment finding the accused guilty beyond reasonable doubt and sentenced each to death, citing aggravating circumstances of nighttime, employment of craft/fraud/disguise, and that the crime occurred in an isolated place; the court gave only the plea of guilty as mitigating circumstance and rejected lack of education as extenuating (citing People v. Mutya). The record did not show that the trial court examined witnesses to establish the aggravating circumstances or otherwise satisfied itself that the illiterate accused fully understood the nature and consequences of their plea.
Because the penalty imposed was the death sentence, the case was brought before the Supreme Court on automatic review. The Supreme Court, En Banc, consider...(Pro-only)
Issues:
- Did the trial court err in accepting the guilty pleas and imposing the death penalty without ascertaining that the accused fully understood the nature and consequences of their plea?
- Could the trial court properly find aggravating circumstances and impose the extreme penalty based solely on the plea of guilty without taking evidence to establish those circumstances, and was the claimed lack of instruction (illiteracy) properly c...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)