G.R. No. L-34091 January 30, 1973
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GEORGE DAENG, CONRADO BAUTISTA, GERARDO ABUHIN, and ROLANDO CASTILLO, defendants-appellants.

FACTS

The defendants-appellants, all inmates at the New Bilibid Prison, were charged with murder for the fatal stabbing of a fellow prisoner on December 13, 1970. The information alleged the qualifying circumstances of evident premeditation and obvious ungratefulness. Initially, all four accused pleaded not guilty at their arraignment on June 28, 1971. However, shortly after the plea, the trial judge addressed them, stating he understood they were “confused” and not ready to plead guilty. He informed them that under Article 160 of the Revised Penal Code, the court had “no alternative except to impose the death penalty” for the crime they had “committed.” He gave them until the next morning to conduct a “soul search” about the consequences, emphasizing the court’s duty to apply the law and that only the executive could grant clemency.
The following day, June 29, 1971, all defendants, assisted by their counsel de oficio, withdrew their not guilty plea and entered a plea of guilty. The trial court immediately accepted the change of plea and, without receiving any evidence, promulgated a decision in open court sentencing all four appellants to death. The case was elevated to the Supreme Court on automatic review.

ISSUE

Whether the trial court committed reversible error in accepting the appellants’ plea of guilty without ensuring it was made voluntarily and with full comprehension of its consequences, and in rendering a judgment of conviction without requiring the prosecution to present evidence.

RULING

Yes. The Supreme Court set aside the decision and remanded the case for a new arraignment and proper proceedings. The Court found the trial judge’s remarks and the subsequent acceptance of the guilty plea procedurally flawed and highly prejudicial. The judge’s statement that the court had “no alternative except to impose the death penalty” for the crime “you have committed” could have been interpreted by the unschooled inmates as a predetermination of their guilt and an inescapable death sentence, potentially coercing a plea out of resignation rather than understanding. This fell far below the exacting standard of care required when accepting a guilty plea, as established in People vs. Apduhan, which mandates that judges must be extra solicitous to ensure the accused fully understands the meaning and import of a guilty plea.
Furthermore, the trial court erred in rendering a conviction based solely on the plea without taking evidence. In capital offenses, the Court has consistently stressed the necessity of requiring evidence despite a guilty plea. This practice is crucial to establish the precise degree of culpability of each accused, clarify the presence of qualifying circumstances, and dispel any doubt that the plea was entered improvidently. The record was devoid of any inquiry by the trial judge to ascertain the appellants’ understanding or the specific details of their participation. Without evidence, it remained possible that some appellants acted only as accomplices or that the crime committed was homicide, not murder, which does not carry the death penalty. The Court also cautioned against the frequent appointment of the same attorney as counsel de oficio, noting potential unfairness to the attorney and inadequate representation for the accused.