- Petitioner
- People
- Respondent
- Intal
- Citation
- G.R. No. L-10585
- Court
- Supreme Court
- Decided
- April 29, 1957
Whether plea of guilty to lesser offense should be considered mitigating circumstance and determination of proper penalty for double homicide
Summary
This criminal case involved Melchor Intal y David, initially charged with double murder who pleaded guilty to the lesser offense of double homicide during trial. The main issue on appeal was whether his plea of guilty should be considered a mitigating circumstance in addition to his physical infirmity. The Supreme Court En Banc ruled that the plea of guilty to an amended charge constitutes a mitigating circumstance, following the precedent in People vs. Calma. With two mitigating circumstances and no aggravating circumstances, the Court reduced the penalty by one degree and applied the Indeterminate Sentence Law, modifying the trial court's sentence from 10 years and 1 day to 17 years, 4 months and 1 day, to 4 years, 9 months and 11 days to 10 years, 8 months and 1 day. The case established important precedent regarding plea bargaining and mitigation in criminal sentencing.
Focus of dispute
Whether plea of guilty to lesser offense should be considered mitigating circumstance and determination of proper penalty for double homicide
Legal facts
Accused initially charged with double murder. During trial, after prosecution rested and defense presented three witnesses, accused manifested willingness to plead guilty to lesser crime of double homicide. Prosecution moved to amend information from double murder to double homicide. Accused pleaded guilty to amended information and requested consideration of physical infirmity as mitigating circumstance, which prosecution admitted. No aggravating circumstances alleged in amended information.
Judgement and reasoning
Court of Appeals: Certified the case to Supreme Court as appeal impugned only the penalty imposed.
Supreme Court En Banc: Modified the penalty. Held that plea of guilty to amended charge should be considered as mitigating circumstance following People vs. Calma precedent. With two mitigating circumstances (plea of guilty and physical infirmity) and no aggravating circumstances, penalty should be one degree lower than prescribed by law. Applied prision mayor in maximum period due to complex nature of offense. Under Indeterminate Sentence Law, imposed penalty of 4 years, 9 months and 11 days of prision correccional (minimum) to 10 years, 8 months and 1 day of prision mayor (maximum).
Trial court: Sentenced accused to indeterminate penalty of 10 years and 1 day of prision mayor (minimum) to 17 years, 4 months and 1 day of reclusion temporal (maximum), plus indemnity and costs. Considered only physical infirmity as mitigating circumstance.