G.R. No. L-14783. April 29, 1961. THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARCIAL AMA Y PEREZ, ET AL., defendants. MARCIAL AMA Y PEREZ, defendant-appellant.
FACTS

Marcial Ama y Perez, along with two others, was charged with murder for stabbing a fellow inmate inside the New Bilibid Prison. The information alleged the special aggravating circumstance of quasi-recidivism, as the accused were serving final sentences at the time. Initially pleading not guilty, Ama later moved to withdraw that plea and substitute it with a plea of guilty. The trial court granted the motion, re-read and explained the information to him with the assistance of his counsel de oficio, after which Ama voluntarily pleaded guilty.
The prosecution objected to defense counsel’s motion for the imposition of the minimum penalty, arguing that the plea of guilty could not offset the special aggravating circumstance of quasi-recidivism, warranting the maximum penalty of death. The trial court required the fiscal to present proof regarding the aggravating circumstance, which was done without objection. Consequently, the court rendered a judgment sentencing Ama to death.

ISSUE

Whether the trial court erred in accepting appellant’s plea of guilty without informing him that such a plea could not offset the aggravating circumstance of quasi-recidivism to avoid the death penalty.

RULING

The Supreme Court affirmed the decision, finding no merit in the appeal. The Court held that the sole duty of the trial court during arraignment is to inform the accused of the nature and cause of the accusation against him to ensure comprehension. There is no legal requirement for the court to advise the accused on the specific penalty that may be imposed upon a plea of guilty, as this duty falls upon defense counsel. In this case, the trial court fulfilled its obligation by re-reading and explaining the information, and even took the extra step of having the prosecution present evidence on the aggravating circumstance for the defense’s perusal.
The legal logic is anchored on established jurisprudence. A plea of guilty, when voluntarily and intelligently entered with the assistance of counsel, constitutes a full admission of all the material facts alleged in the information, including the attendant circumstances. It is sufficient to sustain a conviction, even for a capital offense, without the necessity of further evidence. The presumption of regularity in the performance of official functions by counsel de oficio stands, as there was no record showing a failure to advise the appellant properly. The appellant’s decision to plead guilty, presumed to be based on his conscience and understanding of the charges, must bear its legal consequences. The Court found no improvidence in the plea’s acceptance.