FACTS:

This case involves the review of a judgment by the Regional Trial Court, which found the accused guilty of murder. The crime took place on May 25, 1983, when the victim was fatally stabbed in a public market. The accused, Eugenio Lagarto, was apprehended immediately after the crime. He was charged with murder and pleaded guilty. However, the trial court followed Supreme Court rulings and required the prosecution to present evidence to establish the accused's guilt and degree of culpability.

During the trial, two witnesses testified for the prosecution, and evidence such as the death certificate and the knife used in the crime were presented. The prosecution also introduced the case record of the accused's previous conviction for homicide and an extrajudicial confession where the accused admitted to killing the victim as revenge for his brother's stabbing. The trial court, considering the accused's plea of guilty and the evidence submitted, sentenced him to death. But this penalty was changed to reclusion perpetua, as mandated by the 1987 Constitution.

The accused appealed the judgment, arguing that the trial court was mistaken in recognizing the aggravating circumstances of evident premeditation and treachery and imposing the death penalty. The Supreme Court, in its analysis, acknowledged that a plea of guilty serves as a judicial confession of guilt and that the accused made the plea willingly and voluntarily. As a result, the court upheld the trial court's decision.

ISSUES:

1. Whether the trial court erred in appreciating the aggravating circumstances of evident premeditation and treachery against the accused.

2. Whether the trial court erred in sentencing the accused to suffer the extreme penalty of death.

RULING:

1. The trial court did not err in appreciating the aggravating circumstances of evident premeditation and treachery against the accused. A plea of guilty is a judicial confession of guilt and an admission of all the material facts alleged in the information, including the aggravating circumstances. The accused made the plea freely, voluntarily, and with full knowledge of the consequences and meaning of his act.

2. The trial court did not err in sentencing the accused to suffer the extreme penalty of death. However, the penalty of death had been changed to reclusion perpetua in accordance with the provision of Section 19(1), Article III of the 1987 Constitution.

PRINCIPLES:

• A plea of guilty is a mitigating circumstance and a judicial confession of guilt. It is an admission of all the material facts alleged in the information, including the aggravating circumstances.

• To be considered a true plea of guilty, it must be made by the accused freely, voluntarily, and with full knowledge of the consequences and meaning of his act. It must be made unconditionally.