GR 35963; (March, 1932) (Digest)
G.R. No. 35963 ; March 31, 1932
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. ROMAN CAPA, defendant-appellant.
FACTS
The accused, Roman Capa, pleaded guilty to the charge of triple murder qualified by evident premeditation. He was assisted by his counsel de oficio during arraignment. Before sentencing, his counsel requested the court to consider the mitigating circumstances of passion and obfuscation and lack of instruction, which the prosecution did not oppose. The trial court convicted him based solely on his plea of guilty, without receiving evidence on the circumstances of the crime, and sentenced him to a total of fifty-two years and three days of imprisonment and indemnity.
ISSUE
Whether the trial court erred in convicting and sentencing the accused based solely on his plea of guilty without receiving evidence to determine the circumstances under which the crimes were committed.
RULING
No, the trial court did not err. The plea of guilty was sufficient for conviction. The presence and action of the counsel de oficio, who specifically requested only certain mitigating circumstances after presumably investigating the case details, made a further investigation by the court unnecessary. The counsel’s request implied knowledge of all circumstances and an interest in presenting only those favorable to the accused. The Supreme Court modified the penalty to a total of forty years of imprisonment (applying Article 88, paragraph 2 of the Penal Code on the maximum duration of consecutive penalties) and affirmed the judgment in all other respects.
AI Generated by Armztrong.