Case Summary (G.R. No. L-10585)
Trial Proceedings
While the prosecution had already presented its case and the defense had summoned three witnesses, the appellant expressed his desire to change his plea. Following discussions between the defense and the prosecution, which did not object to the plea change, the court allowed the amendment of the information from double murder to double homicide. The appellant, upon being arraigned under the amended charge and with the assistance of legal counsel, voluntarily pleaded guilty.
Mitigating Circumstances
The appellant asserted the existence of a mitigating circumstance of physical infirmity, which was acknowledged by the prosecution with no counterarguments regarding aggravating circumstances. There was contention, however, regarding whether the appellant’s guilty plea itself could serve as a mitigating factor; the Solicitor General argued that such an offer could not be considered under the Revised Penal Code.
Precedent Consideration
Contrary to the Solicitor General's argument, reference was made to the precedent set in People vs. Calma, where the Supreme Court of the Philippines held that a formal plea of guilty to an amended charge may indeed be taken into account as a mitigating circumstance. The appellant’s plea was thus recognized as an extenuating circumstance in light of this prior ruling.
Sentencing Guidelines
With the recognition of two mitigating circumstances (the plea and the appellant's physical infirmity) and the absence of aggravating factors, the Court determined that the penalty should be reduced by one degree as prescribed by law, leading to the imposition of a sentence of prision mayor. Applying the Indeterminate Sentence Law,
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Case Background
- The case revolves around a trial for double murder where the defendant, Melchor Intal y David, opted to plead guilty to a lesser offense of double homicide.
- The trial court convicted him and imposed an indeterminate penalty ranging from 10 years and 1 day of prision mayor as the minimum to 17 years, 4 months, and 1 day of reclusion temporal as the maximum, alongside indemnity and costs.
Appeal and Certification
- The appeal raised concerns solely regarding the penalty imposed by the trial court.
- The case was certified to the Supreme Court by the Court of Appeals due to the nature of the appeal focusing on legal interpretations of the penalty.
Key Proceedings
- During the trial, after the prosecution rested its case and the defense presented three witnesses, the accused expressed a willingness to plead guilty to double homicide.
- The prosecution, represented by Assistant Fiscal Carlos Gulman Cruz and private prosecutor Atty. Alfonso Felix, Jr., did not object to this motion.
- The trial court allowed the withdrawal of the previous not guilty plea, and the information was amended from double murder to double homicide.