Case Summary (G.R. No. L-63409)
Key Dates
- Judgment promulgated: December 10, 1982
- Initial plea of not guilty entered: July 20, 1981
- Change of plea to guilty: November 15, 1982
- Decision rendered by the Supreme Court: May 30, 1986
Applicable Law
The applicable law for this case includes Article 335 of the Revised Penal Code, specifically concerning attempted rape with homicide, amended by Republic Acts No. 2632 and 4111, as well as Article 68 of the Revised Penal Code regarding penalties for minors below eighteen years of age.
Case Background
Henry Parba was convicted of attempted rape with homicide and initially sentenced to death. His conviction arose from events on March 24-25, 1981, where the victim, Alejandra Dalidig, was attacked and subsequently killed. The critical aspects established during the trial included witness testimonies that indicated the circumstances of the crime, including the recognition of Parba in the vicinity of the crime scene and his subsequent confession to law enforcement authorities.
Change of Plea
On November 15, 1982, after initially pleading not guilty, Parba requested to change his plea to guilty. The prosecution had presented five witnesses prior to this change. The court meticulously ensured that Parba understood the implications of his plea and the nature of the charges against him. The record reflects that Parba was aware of the consequences, affirming that he was admitting the allegations and aggravating circumstances involved.
Trial Court's Acceptance of Guilty Plea
The defense argued that the trial court hastily accepted Parba's guilty plea and did not adequately ensure he understood the full implications of his admission. However, the Supreme Court identified that the trial court acted with the necessary diligence by allowing a postponement for the accused to deliberate on his decision. Parba affirmed his understanding numerous times during the proceedings, indicating that he appreciated the gravity of the situation and the nature of the charges against him.
Misapplication of Mitigating Circumstances
A significant legal question addressed was whether the trial court correctly acknowledged the mitigating circumstance of minority, given that Parba was seventeen years old at the time of the offense. It was established that under Article 68 of the Revised Penal Code, a minor under eighteen years old is entitled to penalties reduced by one or two degrees. The court highlighted that, unlike ordinary mitigating circumstances, the privileged mitigating circumstance regarding minority should be applied.
Conclusion on Se
...continue readingCase Syllabus (G.R. No. L-63409)
Case Background
- The case involves Henry Parba, who was convicted of attempted rape with homicide by the Court of First Instance of Lanao del Norte on December 10, 1982.
- The trial court sentenced Parba to the death penalty and ordered him to indemnify the heirs of the victim, Alejandra Dalidig, in the amount of P12,000.00.
- The case is under automatic review by the Supreme Court as per relevant laws and constitutional provisions.
Plea and Proceedings
- Henry Parba was arraigned on July 20, 1981, where he entered a plea of not guilty.
- The Amended Information against him included aggravating circumstances: the crime was committed in a secluded place, the wrong done was deliberately augmented, and the accused was a recidivist.
- A trial ensued, during which five prosecution witnesses provided testimonies.
- On October 29, 1982, Parba requested time to consider changing his plea.
- On November 15, 1982, he changed his plea from not guilty to guilty, admitting to the allegations made against him.
Evidence Presented
- The evidence presented during the trial included testimonies from eyewitnesses and law enforcement officials, detailing the events surrounding the crime.
- Key witness Roy Salgado testified that he saw the victim being taken by Bonifacio Tolo and later saw Henry Parba in the vicinity.
- The