Case Summary (G.R. No. L-29532)
Procedural History
The case commenced with a criminal complaint of homicide, leading to the arraignment of Oandasan, who initially pleaded “not guilty.” Following elevation to the Court of First Instance, he changed his plea to “guilty.” Before sentencing, Oandasan presented evidence for mitigating circumstances, namely, complete self-defense and voluntary surrender. The trial judge's decision on September 27, 1967, dismissed the plea of guilty as a mitigating circumstance due to the initial plea of not guilty and failed to recognize the claim of incomplete self-defense.
Trial Court's Findings and Ruling
The trial court's ruling resulted in Oandasan being sentenced to an indeterminate penalty of two years, four months, and one day of prision correccional as the minimum, up to eight years of prision mayor as the maximum, alongside an obligation to indemnify the deceased's heirs.
Argument Regarding Plea of Guilty
Oandasan contended that his guilty plea in the Court of First Instance should be afforded mitigating consideration, supported by the Solicitor General. The court recognized a special circumstance in this case; the original plea of not guilty was entered in a preliminary investigation, which does not equivalently apply to a formal trial context. The ruling asserted that since the municipal court could not adjudicate the homicide allegation, the plea's context did not hinder its consideration in the subsequent trial, allowing for the mitigating effect of his guilty plea to be valid.
Argument for Incomplete Self-Defense
Oandasan also sought recognition of the privileged mitigating circumstance of incomplete self-defense, as the situation revealed unlawful aggression from the deceased. The facts indicated that Duldulao actively pursued and assaulted Oandasan’s son, leading to a confrontation in which Oandasan acted in self-defense when attacked. The argument posited that the trial court erred by not acknowledging the deadliness of the aggression and its implication towards establishing a case for incomplete self-defense.
Assessment of Penalty
Analyzing the appropriate penalty, the court referenced Article 69 of the Revised Penal Code to warrant a reduction given the acknowledgment of incomplete self-defense. Coupled with the considerations of voluntary surrender and absence of aggravating factors, the court concurred with the recommendation for a two-degree reduction in penalty.
Final Verdict and Sentence Adjustment
Ultimately, the decision determined that t
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Case Background
- The case involves a criminal complaint for homicide against Mariano Oandasan, who was initially arraigned in the Municipal Court of Flora, Mountain Province, where he pleaded "not guilty."
- The case was subsequently elevated to the Court of First Instance of Cagayan for trial, where a formal indictment for homicide was filed.
- Upon arraignment in the Court of First Instance, Oandasan changed his plea to "guilty" and presented evidence to support claims of mitigating circumstances: incomplete self-defense and voluntary surrender.
Trial Court's Decision
- The trial judge issued a decision on September 27, 1967, ignoring Oandasan's plea of guilty as a mitigating factor due to his prior plea of not guilty in the municipal court.
- The court did not consider incomplete self-defense as a privileged mitigating circumstance; instead, it acknowledged provocation and voluntary surrender as ordinary mitigating circumstances.
- Oandasan was sentenced to an indeterminate penalty of 2 years, 4 months, and 1 day of prision correccional as minimum, to 8 years of prision mayor as maximum, along with an indemnity of P6,000.00 to the heirs of the deceased.
Arguments on Appeal
- Oandasan argued that his plea of guilty should be considered in his favor, a position supported by the Solicitor General.
- The court recognized that a plea of guilty made upon rearraignment in a court of competent