G.R. No. L-14188. March 27, 1961. THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EUTIQUIO YAMSON, ET AL., defendants. EUTIQUIO YAMSON, defendant-appellant.
FACTS

Eutiquio Yamson, a convict serving sentence at the New Bilibid Prisons, was charged with murder for stabbing a fellow inmate, Benjamin Albao, on February 28, 1958. The information alleged the qualifying circumstance of treachery and multiple aggravating circumstances, including quasi-recidivism, insult to public authorities, commission where authorities were discharging duties, use of superior strength, and nighttime. Upon arraignment on March 15, 1958, Yamson, assisted by court-appointed counsel de oficio Atty. Bartolome Felipe, pleaded guilty to the charge. The trial court, after accepting the plea, rendered judgment on May 31, 1958, finding Yamson guilty and imposing the death penalty, considering the sole mitigating circumstance of plea of guilty insufficient to offset the numerous aggravating circumstances. The case was elevated to the Supreme Court for automatic review due to the death penalty imposed.

ISSUE

Whether the trial court validly accepted Yamson’s plea of guilty and correctly imposed the death penalty based on that plea, considering the gravity of the offense and the presence of multiple aggravating circumstances.

RULING

The Supreme Court affirmed the trial court’s judgment, upholding the validity of the plea and the imposition of the death penalty, while modifying the civil indemnity. The Court conducted a review sua sponte to ensure the plea was made with full knowledge of its consequences. The record showed that during arraignment, the trial court informed Yamson of the nature of the accusation, read the complaint, and provided him a copy, all while he was assisted by counsel. The court found the plea was entered “voluntarily and spontaneously.” Citing its prior ruling in a related case involving the same appellant (People v. Yamson, et al., L-14189), the Court emphasized the presumption of regularity in the performance of counsel de oficio’s duties. It noted that neither Yamson nor his counsel complained about the plea at arraignment, during the over two-month interval before sentencing, or after promulgation. This inaction confirmed the plea was intelligently made. Legally, the crime was murder qualified by treachery. The presence of at least five aggravating circumstances, including quasi-recidivism, against only one mitigating circumstance (plea of guilty) justified the imposition of the supreme penalty under the Revised Penal Code. The Court increased the indemnity to the heirs from P3,000.99 to P6,000.00 as recommended by the Solicitor General but affirmed the death sentence in all other respects.