G.R. No. L-55309 February 22, 1982
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALBERTO ABREA y ARANCON, defendant-appellant.

FACTS

The accused, Alberto Abrea, was a detainee at the Zamboanga del Norte Provincial Jail, having been recaptured after escaping from the Davao Prison and Penal Farm. On August 20, 1980, inside the jail compound, Abrea stabbed fellow detention prisoner Anatalio Coca from behind with a hunting knife while the victim was receiving his food ration. Coca died almost instantly from the penetrating stab wound on his back. An amended information charged Abrea with Murder, qualified by treachery and evident premeditation, and alleged the special aggravating circumstance of quasi-recidivism, as Abrea was a previous convict serving a sentence for Robbery with Homicide at the time of the killing.
Upon arraignment, Abrea, assisted by counsel, pleaded guilty to the charge. The trial court conducted a searching inquiry, ensuring he understood the nature of his plea and the possibility of a death sentence. Abrea affirmed his plea and only asked for leniency. The prosecution presented evidence, including an eyewitness account from a fellow detainee and medical testimony, to establish the facts of the crime and the aggravating circumstances.

ISSUE

Whether the trial court correctly imposed the death penalty on the appellant, considering his plea of guilty and the attendant circumstances.

RULING

The Supreme Court affirmed the conviction for Murder but modified the penalty. The legal logic proceeds from an assessment of the plea and the aggravating circumstances. A plea of guilty to a capital offense, while a mitigating circumstance, does not automatically preclude the imposition of the death penalty if sufficiently offset by aggravating circumstances. Here, the crime was qualified by treachery, as the attack was sudden and from behind, ensuring the victim had no chance to defend himself. The special aggravating circumstance of quasi-recidivism was also present and properly alleged, as the accused committed a felony while serving a sentence for another crime.
However, the Court en banc reduced the penalty from death to reclusion perpetua due to the lack of the required number of votes to affirm the capital punishment. The Court noted the trial judge’s own unusual recommendation for executive clemency, citing the victim’s own notoriety and modern penological debates, but this did not constitute a legal mitigating factor. The final ruling is based on the judicial requirement for a specific vote to impose the death penalty, which was not met. The civil indemnity awarded by the trial court was affirmed.