People vs. Juan

The penalty of death cannot be imposed when the crime is attended by a mitigating circumstance of voluntary confession of guilt and no aggravating circumstance, even if the crime is punishable by two indivisible penalties (reclusion perpetua to death); the lesser penalty must be applied pursuant to Article 63 of the Revised Penal Code.

The appellant, Marlon Juan, was charged with parricide under Article 246 of the Revised Penal Code for the killing of his legitimate mother, Yolanda Juan. The crime of parricide is punishable by the indivisible penalties of reclusion perpetua to death. The case came before the Supreme Court on automatic review because the trial court imposed the death penalty, which required confirmation by the High Court.

On April 23, 2001, around 10:00 p.m., Yolanda Juan opened the door of their house to let her son, appellant Marlon Juan, in. Deogracias Juan, Yolanda's husband and appellant's father, was resting inside their bedroom and could hear his wife and son's voices. Appellant, who was high on drugs, demanded delicious food for dinner. Moments later, Deogracias heard the throwing and breaking of plates. He then heard Marvin, appellant's brother, yelling "Ni Nanang natayen" ("Mother is dead already"). Deogracias immediately proceeded to the porch where Marvin's voice came from and saw appellant in the act of stabbing Marvin. Deogracias grabbed the asador (pointed iron bar) from the appellant, and they wrestled for its possession. Eventually, Deogracias got control of the asador. Appellant then drew a knife from his waist and tried to stab Deogracias, but the latter was able to wrest the knife away. Appellant ran away. When Deogracias finally turned his attention to his wife, he realized she was already dead, lying face down on the floor, no longer breathing. Deogracias nevertheless brought her to the hospital, where she was pronounced dead on arrival.

The statement of Marvin Juan that he saw the accused kill their mother was no longer heard by the trial court because the appellant admitted the truth of such testimony. The prosecution formally offered the death certificate and postmortem examination report to prove the death of the victim, and the birth certificate of appellant to prove that he was the legitimate son of the victim. The defense waived the presentation of appellant's evidence. The trial court ruled that it was "clear as the snow of the Alps" that appellant was guilty of the crime of parricide and sentenced him to death. Appellant did not question his conviction but only the penalty of death imposed on him, contending that the proper penalty should be reclusion perpetua.

• Proper Penalty: Appellant contended that the proper penalty imposable on him is reclusion perpetua, not death, given the presence of the mitigating circumstance of voluntary confession of guilt and the absence of any aggravating circumstance.

N/A — The decision does not recount the prosecution's arguments on appeal, as the appellee's position is not detailed in the text.

• Propriety of the Death Penalty: Whether the trial court correctly imposed the death penalty on the appellant for the crime of parricide, or whether he should have been sentenced to reclusion perpetua given the presence of a mitigating circumstance and the absence of aggravating circumstances.

• Propriety of the Death Penalty: No. The death penalty was improperly imposed. Because the appellant was entitled to the mitigating circumstance of voluntary confession of guilt and no aggravating circumstance was alleged or present, Article 63 of the Revised Penal Code required the application of the lesser penalty of reclusion perpetua.

• Propriety of the Death Penalty: Under Article 246 of the Revised Penal Code, the crime of parricide is punishable by reclusion perpetua to death. Since this penalty is composed of two indivisible penalties, the imposition of the proper penalty is governed by Article 63 of the Code. Article 63(2) provides that when there are neither mitigating nor aggravating circumstances, the lesser penalty shall be applied; Article 63(3) provides that when the commission of the act is attended by some mitigating circumstance and there is no aggravating circumstance, the lesser penalty shall likewise be applied. In this case, no aggravating circumstances were alleged in the information, and thus none could be appreciated against the appellant. With respect to mitigating circumstances, the Court found that appellant was entitled to the mitigating circumstance of voluntary confession of guilt under Article 13(7) of the Revised Penal Code. The requisites for this mitigating circumstance are: (1) the accused spontaneously confessed his guilt; (2) the confession of guilt was made in open court before a competent court trying the case; and (3) the confession of guilt was made prior to the presentation of evidence by the prosecution. All three requisites were present: appellant pleaded guilty during arraignment, before the presentation of evidence by the prosecution; he confessed voluntarily and spontaneously despite knowing the serious nature of the charge; and he made his confession openly before the judge and the parties in a hearing. With one mitigating circumstance and no aggravating circumstance, Article 63 mandated the imposition of the lesser penalty of reclusion perpetua, not death. The Court affirmed the trial court's ruling on the conviction itself, as all the elements of parricide were clearly and sufficiently proved: (1) a person was killed, as shown by the death certificate and postmortem report; (2) the deceased was the mother of the accused, as shown by the birth certificate and the appellant's admission; and (3) the deceased was killed by the accused, as shown by his plea of guilty, his admission during pre-trial, and the testimony of his father, Deogracias Juan.

• Mitigating circumstance of voluntary confession of guilt — Under Article 13(7) of the Revised Penal Code, an accused is entitled to the mitigating circumstance of voluntary confession of guilt if he voluntarily confessed his guilt before the court prior to the presentation of evidence by the prosecution. The requisites are: (1) the accused spontaneously confessed his guilt; (2) the confession of guilt was made in open court before a competent court trying the case; and (3) the confession of guilt was made prior to the presentation of evidence by the prosecution. In this case, all requisites were satisfied when the appellant pleaded guilty during arraignment, before the prosecution presented its evidence.

• Application of indivisible penalties under Article 63 — When the law prescribes a penalty composed of two indivisible penalties, the lesser penalty shall be applied when the commission of the act is attended by some mitigating circumstance and there is no aggravating circumstance. The Court applied this rule to reduce the appellant's penalty from death to reclusion perpetua.

• "In this case, no aggravating circumstances were alleged in the information. Thus, no aggravating circumstances can be appreciated against the appellant. With regard to the presence of any mitigating circumstances, we find that appellant is entitled to the mitigating circumstance of voluntary confession of guilt." — This passage establishes the basis for the Court's modification of the penalty, identifying the presence of a mitigating circumstance and the absence of aggravating circumstances.

• "With one mitigating circumstance (voluntary confession of guilt) and no aggravating circumstance, Article 63 of the Revised Penal Code provides that 'in cases in which the law prescribes a penalty composed of two indivisible penalties. . . [the lesser penalty shall be applied] when the [crime] is attended by some mitigating circumstances and there is no aggravating circumstances.' Thus, since the crime of parricide is punishable by reclusion perpetua to death, the lesser penalty of reclusion perpetua should have been imposed by the trial court on appellant, not the penalty of death." — This is the core ratio decidendi of the case, applying Article 63 to the facts and mandating the lesser penalty.

• People vs. Crisostomo, 160 SCRA 47 [1988] — Cited as authority for the requisites of the mitigating circumstance of voluntary confession of guilt.
• People vs. Bueza, 188 SCRA 683 [1990] — Cited as authority for the requisites of the mitigating circumstance of voluntary confession of guilt.

• Article 246, Revised Penal Code — Defines the crime of parricide and prescribes the penalty of reclusion perpetua to death. The Court applied this provision in affirming the appellant's conviction.
• Article 63, Revised Penal Code — Provides the rules for the application of indivisible penalties. The Court applied this provision to determine that the lesser penalty of reclusion perpetua should be imposed, given the presence of a mitigating circumstance and the absence of aggravating circumstances.
• Article 13(7), Revised Penal Code — Defines the mitigating circumstance of voluntary confession of guilt. The Court applied this provision to appreciate the mitigating circumstance in favor of the appellant.

Davide, Jr., C.J., Puno, Vitug, Panganiban, Quisumbing, Ynares-Santiago, Sandoval-Gutierrez, Carpio, Austria-Martinez, Carpio-Morales, Callejo, Sr., Azcuna, and Tinga, JJ., concurred.

N/A — No dissenting opinions are noted in the provided case text.