GR L 15959; (October,1961) (Digest)
G.R. No. L-15959; October 11, 1961
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALFREDO PERALTA, ET AL., defendants, ALFREDO PERALTA and ROMAN FERNANDO, defendants-appellants.
FACTS
Defendants Alfredo Peralta and Roman Fernando, along with four others, were charged with murder for killing Guillermo Lutero inside the New Bilibid Prison on December 26, 1958. The information alleged the qualifying circumstances of treachery and evident premeditation and the special aggravating circumstance of quasi-recidivism, as the accused committed the crime while serving final sentences. Initially pleading not guilty, Peralta and Fernando later withdrew their plea and, with the assistance of counsel de oficio, entered a plea of guilty. The trial court subsequently dismissed the case against their four co-accused due to insufficient evidence.
Upon their plea of guilty, the Court of First Instance of Rizal found Peralta and Fernando guilty of murder. The court appreciated the qualifying circumstance of evident premeditation and the generic aggravating circumstance of treachery, which was offset by the mitigating circumstance of a voluntary plea of guilty. However, the special aggravating circumstance of quasi-recidivism under Article 160 of the Revised Penal Code was applied. Consequently, the court imposed the death penalty, the maximum penalty for murder.
ISSUE
The core issues were: (1) whether the trial court erred in accepting the plea of guilty without first taking evidence to ensure the appellants fully understood its consequences, and (2) whether the allegation of quasi-recidivism in the information was defective for not specifying if the prior convictions were under the Revised Penal Code or a special law.
RULING
The Supreme Court affirmed the trial court’s decision, upholding the death penalty. On the first issue, the Court found no error in the trial court’s acceptance of the plea. The transcript of proceedings clearly showed that both appellants, despite being advised by their counsel de oficio that the maximum penalty would be imposed, insisted on pleading guilty. This demonstrated a clear and voluntary understanding of the plea’s consequences, rendering a further inquiry or presentation of evidence unnecessary.
On the second issue, the Court ruled that the allegation of quasi-recidivism was legally sufficient. For the application of Article 160, it is immaterial whether the crime for which the accused is serving sentence at the time of the new offense is punishable under the Revised Penal Code or a special law. The law’s requirement is simply that the offender is serving a sentence by virtue of a final judgment. Furthermore, the Court examined the prison records and confirmed that both appellants were indeed serving sentences for crimes under the Revised Penal Code—Peralta for robbery and frustrated homicide, and Fernando for homicide—at the time of the murder. Thus, the special aggravating circumstance was properly applied, warranting the imposition of the supreme penalty.