G.R. No. L-32036. July 31, 1973.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANILO VILLAFUERTE, ANTONIO LILA and NICOMEDES BAGAPURO, defendants-appellants.

FACTS

The defendants Danilo Villafuerte, Antonio Lila, and Nicomedes Bagapuro were charged with Murder before the Court of First Instance of Occidental Mindoro. The amended information alleged that on October 29, 1969, they conspired with another individual still at large, armed with bolos, and with intent to kill and treachery, attacked and killed Loreto Mangyan. The information further alleged that Villafuerte was a recidivist, having been previously convicted of frustrated murder, and that all three were quasi-recidivists as they were serving penalties for previous convictions at the time of the commission of the crime.
Upon arraignment, with a counsel de oficio appointed for them, the defendants, through their counsel, signified their intention to plead guilty to the charge and waived the reading of the information. The trial judge, noting the case was serious and could impose the death penalty, instructed the Clerk of Court to read and explain the information to the defendants regarding the consequences of their plea. After this, the counsel de oficio again manifested the accused were willing to plead guilty. The court made a record that the information was read and explained and that the accused were aware the plea could carry the death penalty. Based solely on these pleas, the trial court convicted all three defendants and sentenced them to death.

ISSUE

Whether the trial court committed reversible error in accepting the defendants’ pleas of guilty without ensuring they were entered voluntarily, intelligently, and with full comprehension of the consequences, especially in a capital case.

RULING

Yes. The Supreme Court set aside the judgment and remanded the case for a new arraignment and further proceedings. The legal logic is anchored on the fundamental requirement of due process in accepting pleas of guilty, particularly where the penalty is death. The Court highlighted several critical deficiencies in the trial court’s procedure.
First, the defendants were completely mute throughout the proceedings. They never personally uttered the plea of “guilty” as mandatorily required by Section 3, Rule 118 of the Rules of Court. The plea was communicated solely through their counsel de oficio. This delegation violated the rule that a plea of guilty in a non-minor offense must be entered by the defendant personally in open court to ensure it is their own conscious act.
Second, the trial judge failed to conduct a searching inquiry to ascertain the voluntariness and full comprehension of the plea. The judge merely delegated the crucial task of explaining the information and its consequences to the Clerk of Court. The record is devoid of any dialogue where the judge personally examined the accused to confirm they understood the nature of the charge, the meaning of a plea of guilty, and the severity of the penalty of death. This omission creates serious doubt about whether the defendants, who were also alleged quasi-recidivists, truly grasped the implications of their plea.
Third, the manifestation by their counsel that they were willing to act as state witnesses against a co-accused suggested they might have entertained reservations or were seeking a favorable arrangement, further indicating the plea may not have been unequivocal. Finally, the trial court erred in not taking testimony after the plea of guilty. In capital offenses, jurisprudence consistently holds that courts must still require the prosecution to present evidence to prove the guilt and precise degree of culpability of the accused. This safeguards against the possibility of an improvident plea and provides an adequate record for review. The summary imposition of the death penalty based solely on the counsel’s manifestation, without the accused personally pleading and without any evidence, deprived the Supreme Court of a basis for a fair and