People vs. Perete

A plea of guilt, when formally entered on arraignment, is sufficient to sustain a conviction for a capital offense without the introduction of further evidence, and admits all the material allegations of the information, including attendant circumstances qualifying and/or aggravating the crime. Quasi-recidivism, as a special aggravating circumstance under Article 160 of the Revised Penal Code, raises the penalty to the maximum period prescribed by law for the new felony and cannot be offset by ordinary mitigating circumstances.

Roger Perete was serving a prior sentence at the New Bilibid Prisons in Muntinlupa, Rizal. On March 25, 1959, he and co-accused Victorio Sajorda allegedly attacked and repeatedly stabbed fellow prisoner Receval Langlangan inside the toilet of Dormitory-A, causing the victim’s instantaneous death. Prison guards responded to a routine call and found Perete and Sajorda holding sharp-pointed instruments; the two immediately admitted to the killing. Within hours, both executed extrajudicial confessions detailing the assault.

• The Charge: Roger Perete and Victorio Sajorda were accused of murdering Receval Langlangan on March 25, 1959, inside the New Bilibid Prisons. The information averred that the accused, conspiring together and armed with sharp-pointed instruments, attacked Langlangan with treachery and evident premeditation, inflicting multiple stab wounds that caused instantaneous death. It further alleged that both were quasi-recidivists, having committed the felony while serving sentences after final convictions.

• The Confessions and Immediate Aftermath: On the morning of the killing, prison guard Deogracias Salvador and companions, responding to a call to bring out two prisoners, came upon Perete and Sajorda holding sharp-pointed weapons. Both immediately admitted to having just killed a prisoner. They were taken to the Officer of the Day, where they executed detailed affidavits confessing that they silently pounced on Langlangan in the toilet of Dormitory-A and stabbed him repeatedly. The autopsy revealed no fewer than 41 stab wounds on various parts of the victim’s body.

• Arraignment and Plea: At the June 2, 1959 arraignment, Perete was assisted by counsel de oficio. The information was read aloud and a copy furnished to the accused and his counsel before the plea was taken. Perete pleaded guilty. The trial judge noted that the plea was given “spontaneously and voluntarily.” Neither the accused nor his counsel complained, at any stage, that the plea was improvidently made or not understood.

• Sentencing Without Additional Evidence: The trial court did not receive further evidence for Perete. It found him guilty of murder, appreciated the qualifying circumstances of treachery and evident premeditation and the special aggravating circumstance of quasi-recidivism, and imposed the death penalty, along with an indemnity of ₱6,000 and half the costs.

• Sufficiency of the Plea of Guilt: The People, through the Office of the Solicitor General, countered that the plea of guilt formally entered with assistance of counsel admitted all material allegations of the information and was sufficient to sustain a conviction for a capital offense without further evidence.

• Propriety of the Penalty: The prosecution maintained that treachery and evident premeditation were properly alleged and admitted, qualifying the killing as murder, and that quasi-recidivism as a special aggravating circumstance mandated the maximum penalty of death, rendering any ordinary mitigating circumstances inconsequential.

• Adequacy of the Plea: Whether the trial court erred in convicting appellant on the basis of his plea of guilt without taking additional evidence.

• Qualifying Circumstances: Whether treachery and evident premeditation were properly appreciated in light of the guilty plea.

• Mitigating Circumstances: Whether appellant’s plea of guilt and alleged voluntary surrender should have been credited as mitigating circumstances to reduce the penalty.

• Proof of Quasi-Recidivism: Whether quasi-recidivism was properly appreciated without independent evidentiary proof.

• Adequacy of the Plea: The conviction based on the plea of guilt alone was proper. A plea of guilt, when formally entered on arraignment, is sufficient to sustain a conviction even for a capital offense without additional evidence, as it admits all material allegations of the information, including attendant qualifying and aggravating circumstances. While receiving additional evidence may be the better practice in serious cases, the decision rests in the trial court’s sound discretion. No abuse of discretion was shown; the accused was assisted by counsel de oficio—whose official duty includes advising on the meaning of the plea—and the record contained no complaint that the plea was improvidently given. The trial judge satisfied himself that the plea was entered “spontaneously and voluntarily” after the information had been read and a copy furnished.

• Qualifying Circumstances: Treachery and evident premeditation were properly appreciated. By pleading guilty, appellant admitted the entire information, including the allegation that the attack was carried out with treachery and evident premeditation. The killing was therefore qualified as murder, not homicide.

• Mitigating Circumstances: Even if appellant’s plea of guilt and voluntary surrender were considered mitigating, they could not affect the penalty. Quasi-recidivism, as a special aggravating circumstance, operates to raise the penalty to the maximum period prescribed by law for the new crime. Under Article 160 of the Revised Penal Code, this mandatory elevation cannot be offset by ordinary mitigating circumstances. Thus, the death penalty was unavoidable.

• Proof of Quasi-Recidivism: The appreciation of quasi-recidivism without separate evidence was correct. The information sufficiently alleged its essence—that appellant committed a felony after final conviction and while serving sentence—and the plea admitted that allegation. No further proof was required.

• Plea of Guilt in Capital Offenses — A plea of guilt formally entered on arraignment is sufficient to sustain a conviction for a capital offense without the introduction of further evidence. The plea admits all material allegations of the information, including qualifying and aggravating circumstances. The trial court retains discretion to take additional evidence, but its failure to do so is not an abuse of discretion where the accused is assisted by counsel and the plea is entered voluntarily, spontaneously, and with understanding of its consequences.

• Quasi-Recidivism as a Special Aggravating Circumstance (Article 160, Revised Penal Code) — Quasi-recidivism exists when a person, after having been convicted by final judgment, commits a new felony before beginning to serve the sentence or while serving the same. It is a special aggravating circumstance that mandates the imposition of the penalty in its maximum period. Because it is a special aggravating circumstance, it cannot be offset by ordinary mitigating circumstances. Its presence alone can elevate a penalty to death where the prescribed penalty so permits.

• “It is well-settled that a plea of guilt, when formally entered on arraignment, is sufficient to sustain a conviction even for a capital offense without the introduction of further evidence, and that such plea admits all the material allegations of the information, including the attendant circumstances qualifying and/or aggravating the crime.” — This passage encapsulates the ratio decidendi on the effect of a guilty plea.

• “[Q]uasi recidivism, as a special aggravating circumstance, raises the penalty to the maximum period of that prescribed by law for the new crime committed.” — This excerpt states the non-discretionary effect of quasi-recidivism and explains the inevitability of the death penalty in this case.

• People v. Yamson, G.R. No. L-14189, October 25, 1960 — Cited as controlling authority for the rule that a plea of guilt suffices for conviction without additional evidence and admits all material allegations, including qualifying and aggravating circumstances.

• People v. Ala, G.R. No. L-15633, August 31, 1960 — Followed for the same principle.

• People v. Salazar, G.R. No. L-11601, June 30, 1959 — Followed for the same principle.

• People v. Santos, G.R. No. L-12448, January 22, 1959 — Followed for the same principle.

• People v. Acosta, G.R. No. L-7449, March 23, 1956 — Cited as affirming both the sufficiency of a guilty plea and the trial court’s discretion not to take additional evidence where the plea was made with knowledge of its import.

• Article 248, Revised Penal Code — Defines and penalizes murder. Applied because the information’s allegations of treachery and evident premeditation, admitted by the plea, qualified the killing as murder.

• Article 160, Revised Penal Code (Quasi-Recidivism) — Provides that any person who commits a felony after having been convicted by final judgment, before beginning to serve such sentence or while serving the same, shall be punished by the maximum period of the penalty prescribed by law for the new felony. Applied as a special aggravating circumstance that compelled the death penalty, the maximum period for murder at that time, and could not be negated by ordinary mitigating circumstances.

Bengzon, C.J., Padilla, Bautista Angelo, Labrador, Concepcion, Reyes, J.B.L., Barrera, and Dizon, JJ., concurred.

• None. The decision was unanimous.