Title
People vs. Feliciano
Case
G.R. No. L-3822
Decision Date
Jul 31, 1951
Francisco Feliciano pleaded guilty to homicide with mitigating circumstances, was sentenced, and began serving his term. The court later modified the sentence beyond the 15-day limit, which the Supreme Court ruled null and void, reinstating the original decision.
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Case Summary (G.R. No. L-3822)

Background of the Case

The proceedings commenced with Francisco Feliciano, along with his brothers Ernesto and Fidel Feliciano, charged with murder. Following a preliminary investigation, the Provincial Fiscal opted to pursue the murder charge solely against Francisco Feliciano, moving for the dismissal of the charges against Ernesto and Fidel, which the court accepted. The trial was initially scheduled for January 21, 1950, but was postponed, with the final hearing set for April 4, 1950.

Guilty Plea and Sentencing

On March 30, 1950, prior to the scheduled trial, the court received a plea from the defense counsel, indicating that Francisco Feliciano was willing to plead guilty to homicide rather than murder. The defense requested consideration of two mitigating circumstances: incomplete self-defense of a relative and lack of education. The Provincial Fiscal concurred with the assessment of the facts, leading to Feliciano's guilty plea. Judge Campos, upon hearing the plea, proposed a penalty based on the recommendation made by the Fiscal. Ultimately, Feliciano was sentenced to eight months of "prision correccional" (a form of correctional imprisonment) and ordered to pay P6,000 in indemnity to the deceased's heirs.

Commitment Order and Subsequent Motion

On the same day as the sentencing, an order of commitment was issued, indicating that Feliciano's imprisonment would begin immediately. However, on April 10, 1950, the private prosecutor, Attorney Narciso A. Aquino, filed a motion for reconsideration, asserting that he had been unaware of the March 30 hearing and intended to contest the acceptance of Feliciano's guilty plea. The assistant Provincial Fiscal defended the sentencing decision.

Modification of Sentence

Judge Jose P. Flores reviewed the motion for reconsideration and ultimately issued an order on April 14, 1950, which modified Judge Campos's original decision and imposed a more severe indeterminate penalty ranging from 8 years and 2 months to 15 years and 4 months of "prision mayor," which is a higher degree of penalty than initially executed.

Appellate Review and Decision

Feliciano appealed the decision, contending that the modification of his sentence was void since it was made after the fifteen-day period allowed for such changes had lapsed. Additionally, it was established that Feliciano had already commenced serving his sentence based on Judge Campos's initial decision, which rendered any

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