Case Summary (G.R. No. L-3765)
Charges and Initial Proceedings
Sabilul was charged with murder under the information stating that he unlawfully and feloniously attacked Moro Lario with evident premeditation. During the arraignment, with the assistance of his appointed counsel, Atty. Filoteo Dianela Jo, Sabilul pled guilty. The trial court, without hearing any evidence, dictated a sentence based solely on conflicting statements made by the provincial fiscal and counsel, leading to a significant issue regarding the appropriateness of the plea and resulting sentence.
Trial Court's Findings and Sentencing
The trial court ruled that while Sabilul was guilty of murder, there were mitigating circumstances: the accused acted under the influence of strong emotion, voluntarily surrendered, and entered a plea of guilty. The court stated the penalty should be lower than that prescribed for murder due to these mitigating factors, applying Article 64, paragraph 5 of the Revised Penal Code. Sabilul was ultimately sentenced to six years and one day to eight years in prison, along with a civil indemnity of P2,000 to the victim's heirs.
Appellant's Claims and Legal Errors
On appeal, Sabilul's counsel argued that the trial court erred by not applying the appropriate Article 247 of the Revised Penal Code, which provides for destierro instead of murder. The Solicitor General supported this claim, stating that there may have been a misunderstanding regarding Sabilul's guilty plea. The appellate court found that the proceedings in the lower court were irregular, citing a lack of evidence and a possible misunderstanding regarding the plea entered by Sabilul.
Examination of Procedural Failures
The appellate court criticized the trial court for its failure to take evidence before reaching a decision, emphasizing that a serious crime such as murder cannot be established solely on a guilty plea, especially without supporting evidence or witness testimonies. The procedural errors included claiming mitigating circumstances that were not substantiated by evidence, including that the accused was a "Yakan" belonging to a non-Christian tribe and allegedly ignorant.
Conclusion and Rem
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Case Background
- The case involves the defendant, Moro Sabilul, who was charged with murder in the Court of First Instance of Zamboanga.
- The charge stemmed from an incident on September 14, 1949, in Lamitan, City of Basilan, where Sabilul allegedly attacked and killed Moro Lario using a 'pira,' a traditional Yakan bladed weapon.
- The prosecution claimed that the crime was committed with treachery and evident premeditation.
Proceedings and Initial Plea
- During the arraignment, Sabilul, represented by Atty. Filoteo Dianela Jo, entered a plea of guilty.
- The trial court, presided over by Judge Pablo Villalobos, did not take any evidence but based its decision on conflicting statements from the provincial fiscal and the defense counsel.
- The court sentenced Sabilul to a prison term of not less than six years and one day nor more than eight years of prision mayor, along with a civil indemnity of P2,000 to the heirs of the deceased.
Legal Contentions
- Sabilul appealed the decision, arguing that the trial court wrongly applied Article 248, subsection 1 of the Revised Penal Code concerning murder, rather than Article 247, which provides for destierro (banishment).
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