GR L 24373; (November, 1969) (Digest)
G.R. No. L-24373-74 November 28, 1969
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MANUEL MARQUEZ, TOMAS NAVASCA, ANDRES ALCONTIN, ROGELIO ALCONTIN and FLORENCIO GERALDEZ, defendants-appellants.
FACTS
Criminal Case No. 7050 (for robbery in band with homicide) and Criminal Case No. 7054 (for robbery in band with multiple rape) were filed against the same five defendants-appellants for separate offenses committed in different municipalities and on different dates (May 14, 1961, and April 15, 1961, respectively). The Davao Court of First Instance conducted a simultaneous trial and rendered a single decision convicting all defendants in both cases. The defendants appealed to the Court of Appeals. The Court of Appeals, noting that Case No. 7050 involved a penalty of life imprisonment (within the exclusive appellate jurisdiction of the Supreme Court) and Case No. 7054 involved penalties of reclusion temporal (within its own jurisdiction), and considering that the cases had a consolidated record, common defenses, and identical assigned errors, certified both cases to the Supreme Court to avoid possible conflicting findings and duplication of review. The Supreme Court, however, held that the two crimes were distinct and did not arise from the same occurrence, thus appellate jurisdiction was split by statute.
In Criminal Case No. 7050, at arraignment, accused Tomas Navasca pleaded guilty, contrary to his counsels’ advice. His counsels moved for reconsideration, alleging he had become mentally deranged in prison. The court ordered a psychiatric examination. Dr. Manuel Celis diagnosed Navasca with “schizophrenic reaction,” noting he was hallucinating and had impaired insight but was coherent and relevant in his responses. The trial court maintained that Navasca understood the proceedings and the consequences of his plea.
ISSUE
1. Whether the Supreme Court has appellate jurisdiction over both Criminal Case No. 7050 and Criminal Case No. 7054.
2. Whether the trial court erred in not changing accused Tomas Navasca’s plea of guilty to not guilty based on an alleged mental disorder.
3. What is the correct designation of the crime and the proper penalty for the appellants in Criminal Case No. 7050?
RULING
1. The Supreme Court has exclusive appellate jurisdiction only over Criminal Case No. 7050 because the penalty imposed is life imprisonment. Criminal Case No. 7054, where the penalty is reclusion temporal, falls within the exclusive appellate jurisdiction of the Court of Appeals. The fact that the trial court heard the cases simultaneously and created a consolidated record did not merge the crimes or alter the statutory boundaries of appellate jurisdiction. The two felonies were widely disparate in time and locality and did not arise from the same occurrence. Therefore, the Supreme Court limited its review to Criminal Case No. 7050 and ordered Criminal Case No. 7054 remanded to the Court of Appeals.
2. The trial court did not err in refusing to change Navasca’s plea. The proper remedy if Navasca was insane was annulment of his plea and suspension of arraignment, not a change of plea. The psychiatric report indicated Navasca had a mental disorder but his responses were coherent and relevant, and he reiterated his innocence during examinations. The evidence did not conclusively prove he was legally insane at the time of his plea, i.e., incapable of understanding the charge and its consequences. Thus, his plea of guilty was valid.
3. The crime committed is correctly designated as “robbery with homicide” under Article 294(1) of the Revised Penal Code, aggravated by being committed by a band. For appellants Manuel Marquez, Andres Alcontin, Rogelio Alcontin, and Florencio Geraldez, the presence of the aggravating circumstance of band (with no mitigating circumstance) warrants the imposition of the death penalty under Article 63. For Tomas Navasca, his plea of guilty is a mitigating circumstance offset by the aggravating circumstance of band, resulting in the penalty of reclusion perpetua. The Court affirmed Navasca’s sentence of life imprisonment and imposed the death penalty on the other four appellants. The indemnity to the heirs of the deceased was increased from P6,000 to P12,000, and the indemnity for the robbery was reduced from P1,000 to P856 based on the evidence.