Plea of guilty to capital offense; reception of evidence

As early as in People v. Apduhan, the Supreme Court has ruled that “all trial judges … must refrain from accepting with alacrity an accused’s plea of guilty, for while justice demands a speedy administration, judges are duty bound to be extra solicitous in seeing to it that when an accused pleads guilty, he understands fully the meaning of his plea and the import of an inevitable conviction.”[6] Thus, trial court judges are required to observe the following procedure under Section 3, Rule 116 of the Rules of Court:

SEC. 3. Plea of guilty to capital offense; reception of evidence. — When the accused pleads guilty to a capital offense, the court shall conduct a searching inquiry into the voluntariness and full comprehension of the consequences of his plea and shall require the prosecution to prove his guilt and the precise degree of culpability. The accused may also present evidence in his behalf. (Emphasis supplied)

The requirement to conduct a searching inquiry applies more so in cases of re-arraignment. In People v. Galvez, the Court noted that since accused-appellant’s original plea was “not guilty,” the trial court should have exerted careful effort in inquiring into why he changed his plea to “guilty.”[7] According to the Court:

The stringent procedure governing the reception of a plea of guilt, especially in a case involving the death penalty, is imposed upon the trial judge in order to leave no room for doubt on the possibility that the accused might have misunderstood the nature of the charge and the consequences of the plea.[8]

Likewise, the requirement to conduct a searching inquiry should not be deemed satisfied in cases in which it was the defense counsel who explained the consequences of a “guilty” plea to the accused, as it appears in this case. In People v. Alborida, this Court found that there was still an improvident plea of guilty, even if the accused had already signified in open court that his counsel had explained the consequences of the guilty plea; that he understood the explanation of his counsel; that the accused understood that the penalty of death would still be meted out to him; and that he had not been intimidated, bribed, or threatened.[9]

We have reiterated in a long line of cases that the conduct of a searching inquiry remains the duty of judges, as they are mandated by the rules to satisfy themselves that the accused had not been under coercion or duress; mistaken impressions; or a misunderstanding of the significance, effects, and consequences of their guilty plea.[10] This requirement is stringent and mandatory.[11]

Nevertheless, we are not unmindful of the context under which the re-arraignment was conducted or of the factual milieu surrounding the finding of guilt against the accused. The Court observes that accused Baharan and Trinidad previously pled guilty to another charge – multiple murder – based on the same act relied upon in the multiple frustrated murder charge. The Court further notes that prior to the change of plea to one of guilt, accused Baharan and Trinidad made two other confessions of guilt – one through an extrajudicial confession (exclusive television interviews, as stipulated by both accused during pretrial), and the other via judicial admission (pretrial stipulation). Considering the foregoing circumstances, we deem it unnecessary to rule on the sufficiency of the “searching inquiry” in this instance. Remanding the case for re-arraignment is not warranted, as the accused’s plea of guilt was not the sole basis of the condemnatory judgment under consideration.[12]

Second Assignment of Error

In People v. Oden, the Court declared that even if the requirement of conducting a searching inquiry was not complied with, “[t]he manner by which the plea of guilt is made … loses much of great significance where the conviction can be based on independent evidence proving the commission by the person accused of the offense charged.”[13] Thus, in People v. Nadera, the Court stated:

Convictions based on an improvident plea of guilt are set aside only if such plea is the sole basis of the judgment. If the trial court relied on sufficient and credible evidence to convict the accused, the conviction must be sustained, because then it is predicated not merely on the guilty plea of the accused but on evidence proving his commission of the offense charged.[14] (Emphasis supplied.)


About Erineus

Born on December 28, 1965, Surallah, South Cotabato, Southern Mindanao, Philippines.
This entry was posted in Criminal Law, Plea of Guilty and tagged , . Bookmark the permalink.

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