5. In 1970, Senen Sola was convicted of the crime of frustrated robbery with homicide and sentenced to die. In July 1987, conviction on the ground ofinsufficient evidence. the SC reversed the Furthermore, out of 463 cases where the death penalty was imposed by the trial courts, only 86 were affirmed by the SC. In 297 cases, the death penalty was reducedforvarious reasons. In 53cases, the penalty was reduced based on mitigating circumstances. In 48 cases, it was reduced because the defendants were convicted of the wrongcrime. In 154 cases, it was reduced due to lack of votes and; in 42 cases the convicts were acquitted. After the effectivity of Republic Act No. 7659, the Supreme Court after reviewing the cases imposing death penalty for the accused foundthe following: 1. People v. Alberca - The SC affirmed the guilt of the accused, but, for lack of necessary votes to impose the sentence of death, the Court reduced the accused's sentenceto reclusion perpetua. 2. People v. Godoy - The SC foundthe accused innocentof the crimeofrape. 3. People v. Alicando - The SC annulled and set aside thetrial court's decision and remandedthecaseto thetrial court for further proceeding due to substantive and proceduralerror. 4. People v. Diaz - The SC heldthatthetrial court erred in convicting Diaz without requiring the prosecutionto first prove his guilt and the precise degree of his culpability as required under the Rules of Criminal Procedure. The Court reiterated the mandatory procedure to be followed bytrial courts after an accusedpleadsguilty to a capital offense. 5. People v. Estomaca - TheSCsetaside thetrial court's decision and remanded thecasesto thetrial court for further and appropriate proceedings. 6. People v. Saliling - The SC affirmed thetrial court's decision but modified the penalty by reducing the sentenceto reclusion perpetua. 7. People v. Laurente - The SC modified thetrial court's decision as to the nature ofthe offense committed and reduced the sentence imposedof Laurente. 8. People v. Esparas- (Automatic Review of the Death Sentenceon an accused who,after Arraignment, Escaped andwastried in Absentia.) The Court held that its power to reviewa decision imposing the death penalty cannot be waived either by the accused orby the courts. There is a great possibility that substantial errors committed by trial courts on questions of facts may not be corrected by appellate courts. Under the Philippine procedural law, the Supreme Court usually passes upon questions of law only. It will not ordinarily rule on questions of facts. Thus, convictions are difficult to reverse, as appellate courts will often not consider new evidence - andthefindings of facts oftrial courts are usually conclusive. Ourcriminal justice remains susceptible to humanerror. The judges and eventually the appellate court justices, like anyone else, are prone to commit mistakes as to the guilt of the accused. A mistake that results in the executionof the convicted person can never be undone.