G.R. No. L-29532 - People vs. Oandasan

The criminal complaint was filed for homicide in the Municipal Court of Flora, Mountain Province.
During the preliminary investigation in the municipal court, the accused, Mariano Oandasan, was arraigned and pleaded “not guilty.”
The case was elevated to the Court of First Instance of Cagayan for trial on the merits, where a formal indictment for homicide was filed.
Upon rearraignment in the Court of First Instance, the accused pleaded guilty.
Before the sentencing, the accused presented evidence to establish mitigating circumstances including incomplete self-defense, voluntary surrender, and, controversially, the plea of guilty.

The incident involved the deceased, Quirino Duldulao, who was seen chasing the accused’s son.
After failing to catch the child, Duldulao threw a wooden club at the child.
Mariano Oandasan confronted Duldulao and questioned his actions.
In response, Duldulao struck Oandasan on the left shoulder with the club.
Oandasan, recalling that he had a sharp-pointed knife, drew it.
Duldulao then struck Oandasan on the head with the club, prompting Oandasan to stab Duldulao on the front.
The wounds inflicted on Duldulao were located at the epigastric region and right hand.

The trial judge, in rendering the decision on September 27, 1967, acknowledged some mitigating circumstances:

The judge disregarded the accused’s plea of guilty as a new mitigating circumstance, reasoning that his previous plea of not guilty in the municipal court negated its spontaneity.
Similarly, the trial court did not apply the privileged mitigating circumstance of incomplete self-defense, despite evidence suggesting a partial defense.
The penalty imposed was an indeterminate sentence with a minimum of two years, four months, and one day of prision correccional, and a maximum of eight years of prision mayor, plus additional orders to indemnify the heirs of the deceased and pay costs.

His plea of guilty in the court of first instance should count as a mitigating circumstance because the prior plea in the municipal court was merely part of a preliminary investigation.
The mitigating circumstance of incomplete self-defense should have been recognized given the facts of the case.

The municipal court’s preliminary investigation did not have the jurisdiction to decide on the plea as a mitigating circumstance.
Only the court of first instance, which has proper jurisdiction over homicide, can admit the plea of guilty as a mitigating factor.

The submissions were bolstered by precedents where incomplete self-defense, when combined with other mitigating factors, resulted in a reduced penalty.

Whether the accused’s change of plea—from not guilty in the preliminary investigation to guilty in the Court of First Instance—qualifies as a mitigating circumstance for the purpose of reducing the penalty.

Does a plea of guilty made in the proper forum (the Court of First Instance) override the earlier not guilty plea in the municipal court for mitigating purposes?

Whether the facts of the case justify the recognition of incomplete self-defense as a privileged mitigating circumstance.

Can the elements of unlawful aggression by the deceased and the lack of sufficient provocation on the accused’s part establish a case of incomplete self-defense?

Whether the imposition of the original penalty is appropriate, or if a two-degree reduction of the penalty (under Articles 69 and 64(5) of the Revised Penal Code) is warranted.

Should the benefit of a reduced penalty be extended based on the combined mitigating circumstances of voluntary confession (plea of guilty), incomplete self-defense, and voluntary surrender?