G.R. No. L-72998. July 29, 1988.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANGEL “TOTOY” ACAYA, accused-appellant.

FACTS

The prosecution established that on the evening of July 16, 1983, during a wedding celebration in Batanes, the accused-appellant Angel “Totoy” Acaya stabbed Victor Abad on the left side of the abdomen. The victim was rushed to the hospital but died the following day. Before his death, Abad identified Acaya as his assailant. At his arraignment, Acaya, assisted by counsel, voluntarily entered a plea of guilty to the charge of Murder. The trial court, following procedure, required the prosecution to present evidence to establish the degree of culpability.
The defense, which presented no testimonial evidence, narrated that Acaya was under the influence of liquor during the incident. After the stabbing, the knife was wrested from him, and he was later found by police officers sleeping and heavily intoxicated. The defense emphasized a “blackout” of events for Acaya after the stabbing and presented his sworn statement indicating he had no memory of the events due to intoxication.

ISSUE

The core issues were whether the plea of guilty was valid, whether the aggravating circumstances of treachery and evident premeditation were proven, and whether the mitigating circumstances of intoxication and voluntary surrender should be appreciated.

RULING

The Supreme Court affirmed the conviction for Murder but modified the penalty. The Court held that the plea of guilty was entered voluntarily and with full understanding of its consequences, as the records showed the trial court duly advised the appellant. The claim that counsel requested to change the plea was not substantiated by the transcript.
On the qualifying circumstances, the Court found treachery duly proven. The attack was sudden and unexpected, as the victim was dancing and had no opportunity to defend himself, ensuring the execution of the crime without risk to the assailant. However, evident premeditation and the alleged aggravating circumstance of ignominy were not proven beyond reasonable doubt.
The Court rejected the mitigating circumstance of voluntary intoxication. The defense only proved intoxication after the incident, not at the precise moment of the stabbing. The act of stabbing with a deadly weapon indicated a clear intent to kill, and the presumption of unlawful intent was not rebutted. Voluntary surrender was also not appreciated, as the appellant’s apprehension while drunk and asleep did not constitute a spontaneous intent to submit to authorities.
With the plea of guilty as the sole mitigating circumstance and treachery as the qualifying circumstance, the crime is Murder. Applying the Indeterminate Sentence Law and considering the abolition of the death penalty, the Court modified the penalty to an indeterminate sentence of ten years and one day of prision mayor, as minimum, to seventeen years, four months and one day of reclusion temporal, as maximum. The indemnity was increased to P30,000.00.