G.R. No. L-38833 March 12, 1980
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee vs. AIROL ALING Y MAJURI, accused.

FACTS

Airol Aling, an escapee from the San Ramon Prison and Penal Farm, stabbed and killed Norija T. Mohamad in Zamboanga City on January 28, 1972. In a sworn statement to the police, Aling admitted to the killing, motivated by information received in prison that his wife was unfaithful and living with another man. He recounted chasing and stabbing her upon his arrival home. He was charged with parricide, with the information noting he was a convict serving sentence for robbery with frustrated homicide at the time of the crime.
During arraignment, after several postponements and with the assistance of appointed counsel, Aling pleaded guilty. The trial court conducted a searching inquiry, placing him on the witness stand where he reiterated his confession, affirmed his understanding of the consequences of his plea, and detailed the killing. He stated he was married to the deceased under Muslim rites and they had children. The trial court, finding the plea of guilty to be voluntary and with full knowledge, convicted him of parricide and imposed the death penalty, necessitating automatic review by the Supreme Court.

ISSUE

The core issues for review are: (1) whether the marital relationship between the accused and the victim was sufficiently proven to sustain a conviction for parricide; and (2) whether the accused entered his plea of guilty voluntarily and with full comprehension of its consequences.

RULING

The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua. On the first issue, the Court held that the marital relationship was indubitably established. Aling’s own judicial confession and testimony constituted a clear admission against interest that he was married to the deceased. This was corroborated by the fact they had several children, his reference to his father-in-law, and his stated motive rooted in marital infidelity, all of which reinforced the presumption of marriage under the Rules of Court.
On the second issue, the Court found that the plea of guilty was validly entered. The record showed the trial judge, a Muslim, meticulously complied with the doctrinal requirement for a searching inquiry in capital cases. The arraignment was postponed multiple times to allow counsel to confer with Aling. During the inquiry, Aling testified extensively, confirmed his prior extrajudicial confession, and demonstrated an understanding that his plea could lead to death or life imprisonment. His educational background (first-year high school) further indicated comprehension. However, the Court rejected the mitigating circumstances of plea of guilty, lack of intent, and his status as a non-Christian. The special aggravating circumstance of quasi-recidivism, as he was an escaped convict, was present and could not be offset by ordinary mitigating circumstances. Nonetheless, due to the lack of the necessary votes for imposition of the death penalty, the sentence was reduced to reclusion perpetua.