G.R. No. L-3765 - People vs. Sabilul

The accused, Moro Sabilul, was charged with murder in the Court of First Instance of Zamboanga based on an information alleging that on or about September 14, 1949, within the district of Lamitan, City of Basilan, he maliciously attacked a Moro named Lario using a Yakan bladed weapon (a “pira”), inflicting multiple wounds that resulted in the victim’s death.
Upon arraignment, Moro Sabilul, assisted by his counsel de oficio, Atty. Filoteo Dianela Jo, entered a plea of guilty. The plea, however, appears beset by misunderstanding as to its implications and conditions in relation to the applicable penal provisions.

Without presenting any evidence, the trial court, presided over by Judge Pablo Villalobos, dictated its decision in open court, basing its findings solely on the conflicting statements of the provincial fiscal and the counsel de oficio.
The decision alleged several mitigating circumstances, including:

The decision further stated that, taking into account that the accused was a “yakan” (a member of a non-Christian tribe) and allegedly ignorant, the provisions of section 106 of the Administrative Code for the Department of Mindanao and Sulu should apply.

Based on the trial court’s findings and under Article 248, subsection 1 of the Revised Penal Code (which predetermines Laban’s maximum penalty as death), the court imposed a penalty reduced by one degree (in conformity with Article 64, paragraph 5) due to the cited mitigating circumstances.
Consequently, Moro Sabilul was sentenced to a term of prision mayor, specifically not less than six (6) years and one (1) day and not more than eight (8) years; additionally, he was ordered to pay damages amounting to P2,000 to the heirs of the deceased Moro Lario, along with the accessory penalties and costs of the proceedings.

The defendant, through his counsel, appealed the decision on the ground that the trial court erroneously applied Article 248, subsection 1 of the Revised Penal Code rather than Article 247, which pertains to the imposition of the penalty of destierro.
The Solicitor General argued that there was a misunderstanding regarding the plea of guilty, suggesting that the accused may have conditionally pleaded guilty expecting the imposition of the penalty under Article 247.

No evidence was presented to support the determination of any mitigating circumstances, such as the impulse-induced passion or the alleged voluntary surrender.
The court’s determination that the accused was “hopelessly ignorant” due to his non-Christian background was also made without evidentiary basis.

Both the fiscal’s and counsel de oficio’s conflicting statements were given undue weight, resulting in a sentence dictated without substantiation from any testimonial or documentary evidence.
The record reveals that the accused’s conditional understanding regarding his plea of guilty was not verified or clarified through proper amendment or modification of the information filed by the prosecution.

Whether the trial court erred by accepting a conditional plea of guilty from the accused, given the misunderstanding regarding the applicable penal provision (Article 248 versus Article 247 of the Revised Penal Code).
Whether the trial court should have required additional evidence to independently establish the facts of the case, especially in a serious criminal charge such as murder, rather than relying solely on the plea of guilty.
Whether the trial court’s findings of fact, including the unauthenticated mitigating circumstances and assertions regarding the accused’s background, were supported by evidence and in accordance with procedural safeguards.