Case Summary (G.R. No. L-15633)
Charges and Court Proceedings
Primitivo Ala was charged with murder, specifically for stabbing Artus multiple times, resulting in the latter's instantaneous death. During the arraignment, Ala entered a guilty plea, while Mojica pleaded not guilty. Subsequently, the Court of First Instance of Rizal sentenced Ala to the death penalty and required him to indemnify the victim's heirs. The case was brought before a higher court for review due to the serious nature of the penalty imposed.
Arguments from Defense and Prosecution
Atty. Erlinda Arce Ignacio Espiritu represented Ala and expressed concerns regarding the lack of available evidence for Ala’s actions, attributing this to the guilty plea and the absence of transcribed records from lower court proceedings. She suggested that Ala may not have fully understood the implications of his plea. The prosecution also supported a reconsideration of the case, indicating insufficient evidence against Ala. However, new evidence became available, including a transcript of the plea hearing which clarified the circumstances of Ala’s guilty plea.
Consideration of Guilty Plea
Upon reviewing the transcript, it became clear that counsel for Ala had explained the contents and consequences of the information to him before he expressed his desire to plead guilty. The court confirmed that Ala understood the charges, the voluntariness of his plea, and the potential penalties he faced. These factors substantiate the claim that Ala was aware of the implications of his plea and acted with intent.
Evidence of the Crime
The prosecution's case was significantly bolstered following the conviction of co-defendant Nicolas Mojica, who admitted to killing Artus. Intricately detailed medical findings indicated that the victim sustained thirty-two stab wounds, leading to his death due to internal hemorrhage and shock. The description of the attack confirmed the heinous nature of the crime committed by both defendants, with established intent to kill st
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Case Citation
- Jurisprudence: 109 Phil. 390
- G.R. No. L-15633
- Date: August 31, 1960
Parties Involved
- Plaintiff and Appellee: The People of the Philippines
- Defendants: Primitivo Ala y Duran and Nicolas Mojica
- Defendant and Appellant: Primitivo Ala y Duran
Facts of the Case
- Primitivo Ala and Nicolas Mojica were accused of the murder of Ruperto Artus y Garcia, committed in New Bilibid Prison on March 24, 1959.
- The charge included:
- Conspiracy and mutual assistance in committing murder.
- Use of deadly weapons (sharp-pointed instruments) with evident premeditation and treachery.
- The act resulted in several stab wounds that caused the instantaneous death of the victim.
- Both accused were classified as quasi-recidivists due to committing the felony while serving sentences for prior convictions.
Proceedings and Pleas
- Upon arraignment:
- Ala pled guilty to the murder charge.
- Mojica entered a plea of not guilty.
- The Court of First Instance of Rizal sentenced Ala to the extreme penalty (death), ordered indemnification of the victim's heirs, and payment of costs.
- The trial for Mojica proceeded separately.
Appeal and Legal Representation
- The case reached the Supreme Court en consulta due to the nature of the penalty against Ala.
- Ala's counsel, Atty. Erlinda Arce Ignacio Espiritu, noted the absence of evidence due to Ala's guilty plea, leading to doubts a