Case Summary (G.R. No. L-30343)
Factual Background
On the evening of December 6, 1968, in an isolated area of Catubig, Northern Samar, the accused, armed with bolos, attacked and killed Francisco Lambino. In furtherance of their intent to gain, they stole a pig valued at P100. Mengote and Pajares were subsequently charged with robbery with homicide and entered a plea of guilty to the charge during their arraignment on February 25, 1969.
Proceedings and Pleas
The arraignment included a discussion led by Atty. Manuel Hechanova, who served as the counsel de officio for both defendants. The court allowed time for the defense counsel to complete discussions with the accused, after which they were essentially confirmed to plead guilty. The court accepted their plea without sufficient examination to ensure that the defendants understood the implications of such a plea, especially their admission of committing a capital offense.
Trial Court's Decision
The trial court, in rendering its decision on February 28, 1969, declared the accused guilty beyond reasonable doubt based on their plea. It found the existence of aggravating circumstances such as the crime's commission at night and the use of craft and fraud, while only acknowledging the mitigating factor of their guilty plea. The court sentenced them to death, along with an indemnity of P6,000 to the heirs of the victim, and placed the costs proportionately on the accused.
Review of the Trial Court's Procedure
On review, it was noted that the lower court failed to ascertain whether Mengote and Pajares fully understood the nature of their plea and the consequences of their actions. The judgment highlighted the necessity for trial courts to ensure defendants, particularly those who are illiterate or unschooled, fully comprehend the charges against them and the implications of their pleas. The records showed no inquiry into whether the defendants understood the material allegations in the information or the potential existence of aggravating circumstances.
Conclusion
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Case Overview
- This case involves an automatic review of the judgment rendered by the Court of First Instance of Northern Samar, presided over by Judge Ignacio Mangosing.
- Defendants Severo Mengote and Jose Pajares were convicted of robbery with homicide and sentenced to death.
- They were also ordered to jointly and severally indemnify the heirs of the victim, Francisco Lambino, in the amount of ₱6,000.00 and to cover the proportional share of costs.
Facts of the Case
- On December 6, 1968, in an isolated area of Catubig, Northern Samar, Mengote and Pajares attacked Francisco Lambino, inflicting multiple stab wounds that led to his immediate death.
- The assailants, armed with bolos, also stole a pig valued at ₱100.00 from Lambino.
- The crime occurred at night, in an uninhabited place, employing craft and fraud.
Proceedings Leading to Conviction
- During the arraignment on February 25, 1969, both defendants, represented by counsel de oficio Atty. Manuel Hechanova, pleaded guilty to the charges against them.
- The court did not conduct a thorough examination to ensure the defendants fully understood the nature and consequences of their plea.
- The court acknowledged mitigating circumstances such as vo