GR 133380; (February, 2004) (Digest)
G.R. No. 133380 ; February 18, 2004
PEOPLE OF THE PHILIPPINES, appellee vs. FLAVIANO R. SEGNAR, JR., appellant.
FACTS
Flaviano Segnar, Jr. was charged with Murder for the killing of his sweetheart, Amie Flores. During his arraignment, assisted by counsel, he pleaded guilty to the capital offense. The trial court proceeded to receive evidence from the prosecution, which included the testimony of the victim’s mother and medical and photographic evidence showing the victim’s fatal throat wound. The court then conducted a searching inquiry, questioning Segnar on the stand. Segnar reiterated his guilt, explained his motive, and stated he understood the consequences, even expressing willingness to accept the death penalty. Convinced the plea was voluntary and intelligent, the trial court convicted him of Murder, aggravated by evident premeditation, and imposed the death penalty.
On automatic review, Segnar contended his guilty plea was improvident, arguing he did not fully comprehend its consequences during arraignment. He also challenged the sufficiency of the evidence to prove the qualifying circumstance of treachery, asserting the crime committed was only Homicide.
ISSUE
Whether the trial court erred in accepting Segnar’s plea of guilty and in convicting him of Murder qualified by treachery.
RULING
The Supreme Court affirmed the conviction but modified the crime to Homicide. The Court held that the trial court meticulously complied with the duty to conduct a searching inquiry after a guilty plea to a capital offense. Segnar’s detailed testimony, where he recounted the crime and affirmed his understanding of the penalty, demonstrated his plea was voluntary, intelligent, and improvidently made. However, the conviction for Murder was erroneous. The Information alleged treachery, but the prosecution’s evidence, solely based on the mother’s testimony, failed to establish how the attack was executed. The mere fact that the victim’s throat was slashed does not, by itself, prove that the means of attack was deliberately adopted to ensure its execution without risk to the assailant. With treachery not proven, the crime is properly Homicide under Article 249 of the Revised Penal Code. Considering his voluntary plea of guilty as a mitigating circumstance, the penalty was reduced to an indeterminate sentence. The award of damages was also modified, adding temperate damages for funeral expenses.