Case Summary (G.R. No. 62295-96)
Key Dates
- July 21, 1980: Romeo Pacot first met Yolanda Margate.
- October 1, 1980: Pacot and Margate engaged in their first sexual encounter.
- October 14, 1981: The fatal incident occurred, leading to the stabbings of Yolanda and her children.
- November 9, 1981: Pacot was arraigned and pleaded "not guilty."
- February 8, 1982: Pacot moved to withdraw his plea and instead pleaded guilty.
- March 15, 1982: The lower court issued its decision.
Applicable Law
The crimes were adjudicated under the Revised Penal Code of the Philippines, which governs the crimes of murder and frustrated murder. The case involved the death penalty, which had specific stipulations under Philippine law regarding aggravating and mitigating circumstances.
Case Background
Romeo Pacot, a 23-year-old civil engineering student, began a romantic relationship with Yolanda Margate while she was still in a common-law marriage with Noel Siozon. This illicit affair, which spanned several months, deteriorated when Noel confronted Pacot about his courtship of Yolanda. Despite initial promises to sever ties, Pacot resumed the relationship. On October 14, 1981, during a visit to Yolanda's home, an altercation ensued stemming from Yolanda's frustration over Pacot's reluctance to commit to marriage, which culminated in Pacot stabbing her and her children.
Initial Trial and Sentencing
After the violent incident, three criminal cases were filed against Pacot. Following his initial plea of "not guilty," Pacot changed his plea to guilty upon trial. The trial court, acknowledging the severity of the charges, proceeded to hear evidence despite the plea. The court ultimately convicted Pacot of murder in two cases and frustrated murder in one, emphasizing the presence of numerous aggravating circumstances while recognizing only his plea of guilty as a mitigating factor. He was sentenced to death for the first two murders and to an indeterminate prison term for the frustrated murder.
Appeal and Arguments
Pacot appealed the trial court's decision, arguing:
- He should have been given the benefit of the mitigating circumstances of voluntary surrender, passion, and obfuscation.
- The aggravating circumstances cited in the trial court were incorrectly applied.
- The imposition of the death penalty was unwarranted.
Appellate Court's Findings
The appellate court examined each of Pacot's arguments regarding mitigating circumstances. It concluded that the claim of voluntary surrender was inapplicable, as Pacot did not voluntarily place himself in the custody of the authorities. Furthermore, the court found that the relationship's illegitimacy weakened any claims of passion and obfuscation due to provocation. The violent nature of the crime—specifically, multiple stabbings of victims in an ambush-like setting—properly supported the aggravating factors identified by the trial court.
Modification of Sentencing
While the appellate court affirmed the lower court's convictions, it modified the sentences due to the lack of necessary votes for death penalties. Consequently, Romeo Pacot was sentenced to reclusio
...continue readingCase Syllabus (G.R. No. 62295-96)
Case Overview
- Court: Supreme Court of the Philippines, En Banc
- Date of Decision: March 22, 1984
- Case Numbers: G.R. Nos. L-62295-96
- Parties Involved:
- Plaintiff-Appellee: The People of the Philippines
- Defendant-Appellant: Romeo Pacot y Babad
Background of the Case
- Victims: Yolanda Margate, Dennis Siozon, and Diane Siozon.
- Relationship Context:
- Yolanda Margate was the common-law wife of Noel Siozon, who had two children with her: Diane and Dennis.
- Noel Siozon was previously married to Ophelia Ofinada, from whom he separated.
- Romeo Pacot, a civil engineering student, became romantically involved with Yolanda in 1980.
- Timeline of Events:
- Their relationship developed over several months, leading to sexual encounters.
- The affair became known to Noel Siozon, leading to confrontations and attempts to end the relationship.
- On October 14, 1981, a violent confrontation occurred resulting in the murder of Yolanda and Dennis, and the near-fatal attack on Diane.
Trial and Sentencing
- Charges:
- Three separate criminal cases: Murder for Yolanda Margate and Dennis Siozon, and Frustrated Murder for Diane Siozon.
- Initial Plea:
- Initially pleaded "not guilty" but changed to "guilty" during the trial.
- Sentencing Details:
- For Criminal Case No. 2539 (Yolanda Margate): Death penalty imposed.
- For Criminal Case No. 2541 (Dennis Siozon): Death penalty imposed.
- For Criminal Case No. 2542 (Diane Siozon): Indeterminate penalty ranging from 8 years and 1 day