G.R. No. L-34754 March 27, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SILVESTRE MATE y ABAD, defendant-appellant.

FACTS

An information was filed against Silvestre Mate y Abad and others for Kidnapping for Ransom with Murder and Frustrated Murder. The charges stemmed from a criminal episode on November 1, 1971, in Forbes Park, Makati. The accused, conspiring with others, entered the Butler residence to kidnap Susan and Lyn Butler for ransom. Inside the compound, they were surprised by maid Martina Caldoza, whom they killed by hitting her with a shotgun and stabbing her. When Mrs. Caroline Butler approached, they shot her, inflicting serious but non-fatal wounds. The accused then held Mrs. Butler, threatened to kill her, and successfully extorted a ransom, subsequently kidnapping Suzie Butler.
During his arraignment on November 20, 1971, Mate, assisted by counsel de oficio, pleaded guilty after the court conducted a searching inquiry. The trial court immediately rendered a decision sentencing him to death. Subsequently, the court still conducted hearings where the prosecution presented extensive evidence, including witness testimonies and Mate’s own detailed extrajudicial confessions, which corroborated the facts of the complex crime.

ISSUE

Whether the trial court erred in imposing the death penalty based solely on the accused’s plea of guilty without taking further evidence to ascertain the precise degree of his culpability and the circumstances surrounding the commission of the crime.

RULING

The Supreme Court affirmed the conviction and the imposition of the death penalty. The legal logic rests on the principle that while a plea of guilty is a mitigating circumstance, it does not preclude the court from receiving evidence to determine the correct penalty, especially in capital offenses. In this case, the trial court did not err because, despite the immediate promulgation of judgment following the plea, it subsequently conducted exhaustive hearings. These hearings presented overwhelming evidence, including Mate’s own detailed and voluntary confessions, which thoroughly established his guilt and the precise circumstances of the crime.
The Court rejected the argument that Mate’s voluntary confession indicated insanity or mental aberration. His detailed narration of the crime’s planning and execution demonstrated above-average intelligence and a keen recollection, negating any claim of diminished capacity. The general presumption of sanity prevails, and a confession driven by conscience, even to a capital crime, is not inherently irrational. The evidence conclusively proved the commission of Kidnapping for Ransom with Murder, a crime punishable by death under Article 267 of the Revised Penal Code. The subsequent reception of evidence cured any procedural irregularity and confirmed the propriety of the penalty.