G.R. No. L-30343 - People vs. Mengote

This case is an automatic review of the decision rendered by the Court of First Instance of Northern Samar.
The lower court, presided over by Judge Ignacio Mangosing, convicted Severo Mengote and Jose Pajares for the crime of robbery with homicide.
The decision included sentencing each accused to the extreme penalty of death, ordering them to indemnify the heirs of Francisco Lambino in the amount of ₱6,000.00, and imposing the payment of their proportional share of costs.

On or about December 6, 1968, in the evening, the accused allegedly committed the crime in sitio Canadman (nga Diyo), barrio Manering, Municipality of Catubig, Northern Samar.
The charge stated that the accused, with evident premeditation and in concert with one another, attacked Francisco Lambino; inflicting several stab and slash wounds that caused his immediate death.
In pursuance of their intent to gain, the accused carried away a pig (sow) valued at ₱100.00, which belonged to Vicente Lambino.
The crime was committed at night in an isolated and uninhabited place, with the employment of craft, fraud, and disguise.

On February 25, 1969, the accused were arraigned before the trial court with the assistance of Atty. Manuel Hechanova as counsel de officio.
During arraignment, both accused pleaded guilty after the information was read to them, allegedly doing so voluntarily.
Atty. Hechanova raised mitigating circumstances including:

Voluntary surrender;
Lack of instruction due to the accused being illiterate (Severo Mengote being only Grade One and Jose Pajares having never attended school).
Previous detention, which he requested to be credited in their favor.

The fiscal, however, contended that the mitigating factor of previous detention was not applicable given the gravity of the offense (robbery with homicide).

The trial court accepted the accused’s open plea of guilt without properly examining whether they understood the consequences of their plea, especially the presence and implications of the aggravating circumstances.
Based on the mere admission of guilt during arraignment, the lower court deemed the accused guilty beyond reasonable doubt.
The decision noted aggravating circumstances such as:

The mitigating circumstance of pleading guilty was acknowledged, but the counsel’s invocation of lack of education could not be appreciated as a valid mitigating circumstance.
Consequently, both accused were condemned to suffer the death penalty in accordance with Article 294, sub-paragraph 1, of the Revised Penal Code, along with the additional civil liability imposed.

Whether the trial court, in accepting the plea of guilty from Severo Mengote and Jose Pajares, properly ascertained that they fully understood the nature of the charges and the consequences of their plea, including the imposition of the death penalty.

Did the court ensure that the accused, being unschooled and illiterate, comprehended the technical terms and legal implications of the aggravating circumstances cited?
Was there a sufficient inquiry or evidence presented to confirm that the accused understood that by pleading guilty, they were admitting all the material allegations against them?
Did the trial court exercise the necessary extra precautions, as required in capital cases, to validate the voluntariness and the informed nature of the guilty plea?