**People of the Philippines vs. Juanito Ibañez y Carticiano**
### Facts
On the early morning of October 17, 1996, Felix Olanda and his wife, Rosario Olanda, were sleeping in their home in Poblacion West II, Aliaga, Nueva Ecija. Illuminated by a porch light and a religious altar, the couple was attacked by Juanito Ibañez, who entered their home armed with a bolo. Felix received serious hack wounds but survived due to immediate medical attention, while Rosario was killed instantly by multiple hacks to her neck and head.
Following the incident, Ibañez approached his former employer, Juanito Sarmiento, between 3:00 and 4:00 AM with visible scratches and requested money to leave for another town. On October 20, Sarmiento reported the incident to the police and identified personal items recovered at the crime scene as belonging to Ibañez.
Ibañez was arrested on October 23, 1996, and voluntarily executed an extrajudicial confession with the assistance of Atty. Gavino Villanueva. He was charged with Murder (Criminal Case No. 7564) for Rosario’s death and Frustrated Murder (Criminal Case No. 7563) for Felix’s injuries. Upon arraignment on December 4, 1997, Ibañez, assisted by his counsel de oficio, pleaded guilty.
### Issues
1. **Impropriety of Plea**: Whether Ibañez made an improvident plea of guilty.
2. **Mitigating Circumstances**: Whether the trial court erred in not applying mitigating circumstances such as voluntary surrender, voluntary confession of guilt, and intoxication.
3. **Aggravating Circumstances**: Whether the aggravating circumstances of abuse of superior strength, dwelling, treachery, and evident premeditation were properly considered by the trial court.
4. **Appropriate Penalty**: Proper determination of penalties given the presence of mitigating and aggravating circumstances.
### Court’s Decision
1. **Impropriety of Plea**: The court found that the trial court failed to perform a “searching inquiry” as required by the law to ensure Ibañez’s plea was made with full comprehension and voluntariness. Despite the omission, the adequacy of prosecutorial evidence independently established Ibañez’s guilt beyond reasonable doubt.
2. **Mitigating Circumstances**:
– **Voluntary Surrender**: The court found no voluntary surrender since Ibañez did not submit himself to the authorities but was apprehended after an effort to locate him.
– **Voluntary Confession**: The plea of guilty was acknowledged as a mitigating circumstance but not found to merit a reversible effect.
– **Intoxication**: The court dismissed intoxication as mitigating due to lack of corroborative evidence.
3. **Aggravating Circumstances**:
– **Abuse of Superior Strength and Dwelling**: Errors by the trial court were noted in appreciating these circumstances as they were neither alleged in the informations nor independently constituted when considered.
– **Treachery**: Properly constituted as it was indicated the attack was made while the victims were asleep.
– **Evident Premeditation**: Not duly proven as there was insufficient evidence of prior planning and premeditation stages.
4. **Penalties**:
– In Criminal Case No. 7564 (Murder): The death penalty was found erroneous; the penalty revised to reclusion perpetua, given the presence of a mitigating circumstance and absence of qualifying aggravating circumstances.
– In Criminal Case No. 7563 (Frustrated Murder): The court imposed the penalty of imprisonment ranging from six years and one day of prision mayor as minimum to twelve years and one day of reclusion temporal as maximum.
### Doctrine
The case reinforces the importance of the trial court’s duty to conduct a searching inquiry to avoid improvident pleas in capital cases. Additionally, it establishes the necessity for aggravating circumstances to be alleged in the information to be considered in sentencing.
### Class Notes
– **Elements of Murder**: Intent, treachery, evident premeditation.
– **Frustrated Murder**: Act of execution should produce murder but failed due to timely intervention.
– **Mitigating Circumstances**: Voluntary surrender, plea of guilty.
– **Aggravating Circumstances**: Abuse of superior strength, dwelling, treachery, evident premeditation (need to be alleged in information).
– **Penalties**: Article 248 RPC, Reclusion Perpetua for Murder without qualifying circumstances, Frustrated Murder under Articles 50 and 250 RPC.
### Historical Background
The case occurred amidst a period of stringent crime control policies in the Philippines, with the judiciary taking a firm stance on violent crimes. The trial and subsequent appeal highlight the procedural rigor required in capital cases, reflecting the judiciary’s cautious approach in dealing with pleas involving severe penalties such as death or life imprisonment.
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