G.R. No. 251350 - Cojuangco-Suntay vs. Suntay III

The case involves the People of the Philippines as plaintiff-appellee and Henry Parba as defendant-appellant.
The criminal case (No. 1462) was originally tried in the Court of First Instance of Lanao del Norte (Branch I, Iligan City).
On December 10, 1982, the trial court found Henry Parba guilty beyond reasonable doubt of attempted rape with homicide and sentenced him to death, with corresponding accessories.
The judgment also imposed an indemnification of P12,000.00 to the heirs of the deceased, Alejandra Dalidig, plus costs.

The prosecution presented five witnesses whose testimonies established the material facts of the crime:

Seeing Bonifacio Tolo escort the victim, Alejandra Dalidig, into an unoccupied hut.
Noticing the accused in the vicinity by the light of a fluorescent lamp.
Witnessing the sequence wherein the victim was seen inside the hut with Bonifacio Tolo, and later, again, with Henry Parba.

Sgt. Francisco Englatiera’s early morning observation on March 25, 1981, revealed:

A crowd gathered around a hut.
The discovery of the victim’s body with several stab wounds covered with banana leaves.

Additional testimonies of Pat. Milo Paredes, Dr. Livey Villarin, and Ludovina Frasco supported the sequence of events.

Documentary evidence was introduced in the form of multiple exhibits (Exhibits A, A-1, A-2, A-3, A-4, B, B-1, C, C-1, C-2, D, and E).

Initially, Henry Parba pleaded not guilty when arraigned on July 20, 1981, under an amended information charging him with attempted rape with homicide.
The accused, through his counsel de oficio, requested a postponement to reconsider his plea, aiming to study withdrawing his plea of not guilty and substituting it with a plea of guilty.
On the rescheduled trial date (November 15, 1982), the court allowed him to change his plea after:

The court read and explained the amended information, including the relevant aggravating circumstances.
The proceedings were conducted with the aid of a court interpreter who translated into the Bisayan dialect, ensuring the accused’s full comprehension.

During the session, the court questioned both the accused and his counsel about:

The meaning and legal consequences of the plea.
The acknowledgment of aggravating circumstances, such as the crime being committed in a secluded place and the deliberate augmentation of wrong.

The accused affirmed, both verbally and in writing (a second time at the police station), that he understood the information and the consequences of his plea of guilty.

The trial court sentenced Henry Parba to the supreme penalty of death, in addition to other accessory penalties.
On appeal, two issues were raised by the appellant’s counsel:

The claim that the trial court improvidently accepted the plea of guilty, arguing that the accused did not fully understand the gravity and consequences of his plea.
The contention that the trial court ignored the privileged mitigating circumstance of minority, as Parba was 17 years old at the time of the offense, despite the mandatory death penalty prescribed for the capital offense.

Whether the trial court improperly accepted the plea of guilty due to an alleged lack of full understanding on the part of the accused.

Did the court exercise sufficient patience and circumspection in explaining the nature, meaning, and consequences of the plea?
Was the accused, accompanied by his counsel de oficio and aided by a competent interpreter, fully aware that his guilty plea constituted an admission of all allegations in the information?

Whether the trial court erred in disregarding the privileged mitigating circumstance of minority in imposing the penalty.

Given that Henry Parba was 17 years old at the time the crime was committed, should Article 68 of the Revised Penal Code have been applied?
Does the application of Article 68 allow for a reduction of the prescribed penalty from death to a lesser sentence, considering the offense's mandatory penalty rules?