Case Summary (G.R. No. L-32623)
Charges and Allegations
The information presented against Fernandez and his co-defendants claims they committed theft of PHP 350.00 from Sebastian Espelita, Sr., utilizing force and violence. The defendants are also accused of attacking Sebastian Espelita, Jr., leading to a wounded chest injury, as well as assaulting and fatally wounding four others, including pregnant Dolores Espelita. The Commission of this crime took place during nighttime, denoted in the information.
Plea and Trial Court Judgment
Upon arraignment, Fernandez, represented by court-appointed counsel, pleaded guilty after being informed about the charge's significance and the potential penalty. The trial court subsequently determined that the crime constituted “Robbery with Frustrated Homicide and Multiple Homicide," under Article 294 of the Revised Penal Code, carrying a penalty ranging from reclusion perpetua to death. The court acknowledged Fernandez's guilty plea as a mitigating circumstance and sentenced him to the death penalty along with an indemnification of PHP 12,000 to the heirs of each deceased victim.
Review of Sentencing
The appeal presented by Attorney Honorio Poblador, Jr., appointed for this review, questioned the appropriateness of the death penalty given the mitigating circumstance of the guilty plea and no identified aggravating circumstances. While the trial court mentioned that the crime was committed at night, the appeal argued that this circumstance did not fulfill the requirements to qualify as an aggravating factor under Article 14(6) of the Revised Penal Code, which stipulates that nocturnity must enhance the likelihood of success or facilitate the crime.
Judicial Findings on Nocturnity
The court noted that the mere mention of the crime's occurrence at night did not satisfy the criteria necessary to consider it an aggravating circumstance. Additionally, if nocturnity were regarded as aggravating, it would offset the mitigating circumstance of the guilty plea. Article 63(2) of the Revised Penal Code provide
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Case Overview
- The case involves the mandatory review of a death penalty imposed by the trial court on Enrique Fernandez, who was convicted of "Robbery with Frustrated Homicide and Multiple Homicide."
- The conviction stemmed from a violent incident on January 4, 1970, in Barrio La Suerte, City of Pagadian, Philippines, where Fernandez and three co-defendants attacked the Espelita family.
- The trial court's decision was based on Fernandez's guilty plea, despite the serious nature of the charges against him.
Charges and Allegations
- Nature of the Crime: The accused were charged with robbery accompanied by frustrated homicide and multiple homicide.
- Specific Acts: The defendants were alleged to have:
- Used force and violence against Sebastian Espelita, Sr., stealing P350.00 from him.
- Attacked Sebastian Espelita, Jr. with hunting knives, resulting in injuries but not death due to medical intervention.
- Fatally assaulted Sebastian Espelita, Sr., Dolores Espelita, George Espelita, and Alejandra Espelita, resulting in their deaths.
- Notably, Dolores Espelita was pregnant at the time of her death.
Court Proceedings
- Arraignment: During his arraignment, Fernandez was assisted by a court-appointed attorney and entered a plea of guilty after being informed of the serious charges