G.R. No. L-34841, January 22, 1980
The People of the Philippines, plaintiff-appellee, vs. Benjamin Retania y Rodelas, accused-appellant.

FACTS

Benjamin Retania was charged with robbery with homicide for killing an 11-year-old boy and stealing a transistor radio. The information alleged several aggravating circumstances, including quasi-recidivism as Retania was a prisoner who had escaped. Upon arraignment with the assistance of counsel de oficio, Atty. Alfonso Adora, Retania pleaded guilty after a five-minute consultation. The trial court promptly rendered a decision imposing the death penalty. The case was elevated to the Supreme Court for automatic review.
During the appeal, Retania’s new counsel de oficio, Atty. Teresita Cruz Sison, filed an omnibus motion alleging that the accused exhibited signs of mental disorder, such as a flat affect and lack of emotional response, which could indicate schizophrenia or mental retardation. She requested a mental examination and suspension of the briefing period. The Solicitor General submitted a certification from a prison psychiatrist stating Retania was mentally normal. Counsel then filed a brief, arguing the plea was improvident and due process was violated.

ISSUE

Whether the trial court committed a reversible error by accepting Retania’s guilty plea without conducting a proper searching inquiry to ensure the plea was made voluntarily and with full comprehension of its consequences.

RULING

Yes. The Supreme Court set aside the conviction and remanded the case for further proceedings. The Court emphasized that a plea of guilty to a capital offense demands the highest degree of scrutiny. The trial court has a mandatory duty to conduct a searching inquiry into the voluntariness and full comprehension of the accused. This inquiry must ensure the accused understands the nature of the charge, the meaning of his plea, and the precise consequences, including the specific allegations and the severity of the penalty.
The record revealed a grossly insufficient compliance with this duty. The consultation between Retania and his counsel lasted only five minutes before the arraignment. More critically, the trial court failed to explain the complex allegations in the information, particularly the specific aggravating circumstances like cruelty and abuse of superior strength. Merely translating the information into Tagalog was inadequate. The court did not ascertain if Retania understood how his actions constituted these qualifiers or the implications of quasi-recidivism. Furthermore, the court did not require the prosecution to present evidence to substantiate the plea and establish the precise degree of culpability. Given the gravity of the death penalty, such procedural shortcuts deprived the accused of due process. The plea was therefore deemed improvident. The case was ordered returned to the trial court for re-arraignment and a new trial where the prosecution must prove its case with evidence.