Case Summary (G.R. No. L-47462)
Procedural Background
After being arraigned and pleading not guilty alongside four co-accused, Parohinog sought to change his plea to guilty for the lesser offense of homicide. This change was consented to by the prosecution. However, following a witness's testimony, Parohinog’s counsel filed a motion to revert the plea back to not guilty, claiming he did not comprehend the guilty plea’s consequences. The trial court allowed this motion, but ambiguity arose regarding whether it reinstated the not guilty plea or merely withdrew a change of plea procedure.
Legal Issues Presented
The central legal question of this case was concerning the implications of Parohinog’s plea changes after the prosecution had already presented its case. The trial court's order left open interpretations about whether the guilty plea to homicide reverted to a not guilty plea to murder after the defense motion. This confusion could inherently affect the assessment of culpability and potential conviction.
Analysis of Evidence
The trial court recognized the absence of aggravating factors that would elevate the offense to murder and determined that Parohinog was entitled to mitigating circumstances stemming from immediate vindication of a grave offense, as well as voluntary surrender. These aspects were key in recalibrating the conviction from murder to homicide, as it was clear from the evidence presented that the legal requirements for a murder charge were not met.
Conclusion of the Court
The ruling modified the trial court's decision, ultimately convicting Wilson Parohinog only of homicide, with a reevaluation of the penal
...continue readingCase Syllabus (G.R. No. L-47462)
Procedural Background
- Wilson Parohinog, along with several co-accused, was charged with murder in the Court of First Instance of Capiz, under Criminal Case No. 121.
- Upon arraignment, all accused pleaded not guilty.
- After the prosecution rested its case, Parohinog expressed the desire to change his plea from not guilty to guilty for the lesser offense of homicide, which the prosecuting fiscal agreed to.
- Following the re-arraignment, Parohinog pleaded guilty to homicide, but sentencing was postponed, and the trial continued.
Motion to Change Plea
- On March 16, 1973, Parohinog's counsel filed a written motion to revert his plea from guilty to not guilty, citing lack of comprehension regarding the consequences of his initial plea and the existence of a valid defense.
- The trial court issued an order granting the motion but the order was vague and open to interpretation.
- The ambiguity of the order led to two interpretations: one where the plea of guilty to homicide was withdrawn, and another where the plea reverted to not guilty for murder.
Legal Questions and Implications
- The key legal question arose regarding the implications of the plea of guilty to homicide after the prosecution had rested its case.
- If evidence presented constitu