G.R. No. 139907 - People vs. Bates

The case involves the appellant, Sy Chay (alias See Kuan), charged with the crime of theft.
The stolen property in question consisted of melons belonging to Lazaro Crufc.
The appellant had a prior criminal record, having been previously convicted of theft on four separate occasions:

At arraignment in the Court of First Instance, the appellant initially denied any participation in the crime.
Despite the initial denial—including during preliminary proceedings in the municipal court—he eventually admitted his guilt when the case was heard in the Court of First Instance.
Evidence had to be taken because of his initial denial, but his later admission was construed as an acceptance of the multiple circumstances under which the offense occurred.
The case discussions reference earlier jurisprudence (People vs. Hermino and others) concerning the proper timing and nature of a voluntary confession.

Three months and one day of arresto mayor for the crime of theft.
Ten years and one day of prision mayor for being a habitual delinquent, specifically due to his fifth instance of recidivism.

Additionally, the appellant was ordered to indemnify the owner of the melons in the sum of P5.
The determination of penalty lengths was based on the degree of aggravating circumstances, primarily his recidivist status.

The appellant argued that the trial court erred by not considering his confession as a mitigating circumstance.

He contended that his voluntary confession should have mitigated the penalty.
He maintained that such mitigating circumstance should be set off against the aggravating factor of recidivism.

The appellant also challenged the application of subsection 5 of article 62 of the Revised Penal Code, claiming it was unconstitutional.

Further, the appellant argued that the sentences imposed for both theft (arresto mayor) and habitual delinquency (prision mayor) were erroneous and excessive.

Whether the appellant’s confession, later admitted during trial, qualifies as a voluntary confession that can be considered a mitigating circumstance in reducing his penalty.

The issue revolves around the timing and nature of the confession.
Whether a confession admitted after initial denials loses its mitigating effect due to the lack of evidence of genuine repentance or timely submission.

Whether the application of subsection 5 of article 62 of the Revised Penal Code—especially its provisions concerning recidivism and habitual delinquency—is constitutional.

The appellant claimed that these provisions were unconstitutional because they impose an additional penalty that is akin to ex post facto punishment.
Whether these statutory provisions, when combined with the appellant’s record as a repeat offender, justify the severe sentence imposed.

Whether the sentencing of three months and one day of arresto mayor for the crime of theft was in accordance with law.

This involves assessing if the penalty imposed falls within the statutory limits given the circumstances and the value of the stolen item.

Whether the imposition of ten years and one day of prision mayor for habitual delinquency was proper and constitutional.

This issue analyzes if the appellant, as a habitual delinquent, has been correctly punished in light of his repeated offenses within a prescribed period.