G.R. No. L-35969 May 16, 1980
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CELESTINO VILLACORES, ROMULO LIRIO, PEDRO DUCAY and ABIS GAMONGAN, defendants-appellants.

FACTS

The appellants, prisoners at the New Bilibid Prison, were charged with Murder and Multiple Frustrated Murder for a stabbing incident on May 4, 1972, resulting in the death of Romeo Domingo and injuries to three others. Upon arraignment, all four accused, with the assistance of counsel de oficio, pleaded guilty. The trial court, after informing them in Tagalog of the consequences and the imposable death penalty, accepted their reiterated pleas. It then rendered a judgment finding them guilty beyond reasonable doubt and sentencing them to death.
However, citing the doctrine in People v. Epifanio Flores, the trial court simultaneously ordered the Special Prosecutor to present evidence to determine the degree of the accused’s culpability. Evidence was subsequently presented over two hearing dates. After the prosecution rested, the trial court issued an order affirming the death sentence and forwarded the records for automatic review.

ISSUE

Whether the trial court committed reversible error in convicting the appellants based on their plea of guilty and in its procedure of taking evidence after the judgment.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The legal logic centers on the propriety of taking evidence after a plea of guilty in capital offenses. The Court held that the trial court’s procedure was correct and prudent. The purpose of such post-plea evidence is twofold: to remove any doubt that the accused fully understood the consequences of their plea, and to provide a factual basis for the Supreme Court’s automatic review, particularly for determining the precise degree of culpability and the presence of aggravating or mitigating circumstances. There is no law prohibiting the taking of testimony after a plea of guilty; in fact, it is deemed essential for a conscientious review in death penalty cases.
However, upon its review of the evidence taken, the Supreme Court found that the qualifying circumstances alleged in the information were not sufficiently established. The evidence did not adequately prove evident premeditation or treachery. Conversely, a mitigating circumstance—that of lack of intent to commit so grave a wrong—was present, as the appellants’ prior agreement was merely “to stab” (manaksak), not necessarily to kill. Consequently, the crimes were properly classified as Homicide and Multiple Frustrated Homicide, not Murder. The Court modified the penalty from death to an indeterminate sentence for each appellant, the maximum of which should be within the minimum period of the penalty for homicide. The awards for indemnity and damages were affirmed.