G.R. No. L-38626 March 14, 1975
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. STEPHEN DOUGLAS STRONG alias STEVE STRONG, defendant-appellant.

FACTS

This is an automatic review of a death sentence. The accused, Stephen Douglas Strong, was charged with robbery with homicide. During his arraignment, he initially entered a plea of guilty to the charge. The trial judge, Judge Jesus V. Occena, then proceeded to conduct a searching inquiry by reading the specific allegations from the information, including that the accused, with intent to kill, attacked, assaulted, stabbed, choked, and strangled the victim Cornelia Bartolaba with a fork and towel, causing her immediate death.
When asked by the judge what he had to say to that specific allegation, the accused answered “No.” The judge then interrogated him further, asking if he meant to deny that he attacked, assaulted, stabbed, choked, or strangled the victim. To each separate question, the accused consistently answered “no,” outrightly denying the commission of the acts attributed to him.

ISSUE

Whether the trial court erred in convicting the accused based on his initial plea of guilty despite his subsequent categorical denials of the criminal acts during the searching inquiry.

RULING

Yes. The Supreme Court set aside the conviction and remanded the case for a proper trial. The Court ruled that the plea of guilty could not be considered definite, absolute, or informed under the circumstances. The constitutional due process requirement for accepting a plea of guilty in a capital offense was blatantly disregarded.
The legal logic is anchored on the well-settled doctrine that a plea of guilty must be unconditional and made with full comprehension of its consequences, especially in capital cases. When a plea is ambiguous or not absolute, it is equivalent to a plea of not guilty. Here, the accused’s explicit and repeated denials of the factual allegations during the judge’s questioning rendered his initial plea ambiguous and ineffective. The trial court was therefore mandated to enter a plea of not guilty and proceed to trial on the merits.
The Supreme Court, citing its constant admonition in cases like People v. Apduhan, emphasized the trial judge’s duty to be extra solicitous and circumspect in ensuring an accused fully understands the meaning and import of a guilty plea. By convicting the accused based on the improvident plea despite the clear denials, the trial judge acted with judicial carelessness, violating fundamental procedural principles and the accused’s right to due process. The judgment was nullified, and a new trial was ordered.