Case Summary (G.R. No. L-2822)
Proceedings and Plea Change
During the trial, after the testimony of two prosecution witnesses, Teofilo Mari withdrew his initial plea of not guilty and entered a plea of guilty. The trial continued against the co-accused, Guevarra. Ultimately, the court found Guevarra guilty of conspiring with Mari to steal the vehicle.
Sentencing and Legal Framework
Upon entering his guilty plea, Teofilo Mari was sentenced to a prison term of 4 years, 2 months, and 1 day of prision correccional to 8 years and 1 day of prision mayor. The appeal primarily focused on the legality of the imposed sentence in relation to the provisions of Republic Act No. 120, which amends Article 310 of the Revised Penal Code, classifying the theft of a motor vehicle as qualified theft and escalating the penalties for such an offense.
Classification of Theft and Applicable Penalties
The revised Article 310 designates that the penalties for theft are to be increased by two degrees for certain categories of stolen items, including motor vehicles. In accordance with Article 309, ordinary theft of property valued at P1,500 falls under the minimum and medium periods of prision correccional. Therefore, qualified theft involving a motor vehicle carries penalties of prision mayor for the medium and maximum terms.
Deliberation on Mitigating Circumstances
The court ruled that Teofilo Mari's guilty plea did not constitute a mitigating circumstance since the plea was entered after the prosecution had presented evidence. Previous rulings established that a voluntary confession must occur before any testimony for it to be considered mitigating.
Final Ruling and Adjustments
In light of the guidelines established
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Case Citation
- Court: Supreme Court of the Philippines
- Date: October 13, 1949
- G.R. No.: L-2822
- Reporter: 84 Phil. 738 EN BANC
Parties Involved
- Plaintiff: The People of the Philippines
- Defendant: Teofilo Mari y Duran
- Co-Accused: Joven Guevarra y Castro
Summary of Facts
- Teofilo Mari and Joven Guevarra were jointly prosecuted for qualified theft.
- The information alleged that on or about January 2, 1943, both accused conspired to steal a Ford civilian jeep owned by Sy Chit, valued at P1,500.
- A joint trial commenced in January 1949.
- After two prosecution witnesses had testified, Teofilo Mari withdrew his plea of not guilty, opting instead to plead guilty.
- The trial continued against Joven Guevarra, who was found guilty of stealing the jeep in connivance with Mari.
Proceedings and Rulings
- Upon accepting Mari's plea of guilty, the court sentenced him to imprisonment ranging from 4 years, 2 months, and 1 day of prision correccional to 8 years and 1 day of prision mayor.
- Mari subsequently appealed the sentence, with the appeal focusing solely on a question of law regarding the appropriateness of the sentence.
Legal Framework
- Statute Involved: Republic Act No. 120, effective June 14, 1947, amended Article 310 of t