G.R. No. L-77685. April 15, 1988.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NESTOR ENCISO alias “DAGUL,” JESSIE ABE SUYONG, and ARMANDO BALASBAS, accused-appellants.

FACTS

The body of 13-year-old balut vendor Norberto Lonzaga was discovered with multiple stab wounds in Mandaluyong on November 18, 1980. Police investigation led to appellants Nestor Enciso, Jessie Suyong, and Armando Balasbas, who were seen with the victim prior to the incident. Enciso and Balasbas were apprehended in their shanty, where Enciso admitted to the stabbing and implicated his co-accused. Suyong was later arrested. All three executed sworn statements detailing their roles and participated in a crime re-enactment. An information for robbery with homicide was filed, alleging they conspired to rob and kill Lonzaga for P21.00.
Upon arraignment, all initially pleaded not guilty. However, during the March 3, 1981 hearing, Enciso and Suyong, through counsel, moved to withdraw their pleas and instead pleaded guilty to the capital offense. The trial court, noting the gravity of the crime, ordered the prosecution to present evidence to establish the precise degree of culpability and ensure the voluntariness of the pleas, despite the guilty pleas already entered.

ISSUE

Whether the guilty pleas of accused-appellants Enciso and Suyong are sufficient to sustain their conviction for robbery with homicide, and whether the trial court erred in still requiring the presentation of evidence after the pleas were entered.

RULING

The Supreme Court affirmed the conviction of Enciso and Suyong but acquitted Balasbas. The trial court correctly required the prosecution to present evidence notwithstanding the guilty pleas. In capital offenses, a plea of guilty does not automatically justify conviction; the court must ensure the plea was entered voluntarily and with full comprehension of its consequences. More critically, the court must still inquire into the precise liability of the accused by requiring the prosecution to prove the crime and the aggravating circumstances alleged. This mandatory procedure safeguards the accused’s rights and provides an independent basis for the judgment.
Here, the prosecution complied by presenting evidence, including the sworn statements and the testimony of co-accused Armando Balasbas. Balasbas’s testimony in court corroborated the conspiracy, identifying Enciso as the one who stabbed the victim and Suyong as the one who held the victim. This testimony, coupled with their own extrajudicial confessions, constituted proof of guilt beyond reasonable doubt for Enciso and Suyong. Their subsequent attempts to recant their pleas and deny involvement were properly disregarded, as a plea of guilty, when voluntarily made, is a judicial admission of all the facts alleged in the information. Regarding Balasbas, the Court concurred with his acquittal. The trial court’s factual recital showed he did not actually participate in the killing or the division of the loot. Without his extrajudicial confession, which was insufficient alone for conviction, there was no evidence to prove his guilt beyond reasonable doubt.