G.R. No. L-73314 March 20, 1986
PEOPLE OF THE PHILIPPINES, petitioner, vs. BENEDICTO CASTANIO, respondent.

FACTS

Accused Benedicto Castanio was charged with Murder. Upon arraignment, assisted by counsel de oficio, he pleaded guilty. The trial court apprised him of the consequences, including the imposable death penalty, but Castanio insisted on his plea. In its 1972 decision, the trial court found him guilty beyond reasonable doubt based on his plea and sentenced him to death. Paradoxically, the same decision, citing the accused’s remorse, recommended executive clemency to commute the penalty to life imprisonment. Furthermore, invoking the doctrine in People vs. Flores, the court ordered the prosecution to present evidence to determine the accused’s state of culpability.
Thirteen years later, in 1985, the trial court, now under a different judge, attempted to comply with this directive by setting a hearing. However, the prosecution failed to present its witnesses as they were no longer available. Consequently, the trial court elevated the records to the Supreme Court for final disposition. The records lacked a transcript of stenographic notes, leaving the court’s recitals in the decision as the primary source of the proceedings.

ISSUE

Whether the trial court’s acceptance of the accused’s plea of guilty to a capital offense, without taking further evidence to ascertain his full comprehension of its consequences, was valid and sufficient for the imposition of the death penalty.

RULING

No. The Supreme Court remanded the case to the trial court for a new hearing. The Court restated the norm from People vs. Flores and People vs. Estebia: in capital offenses where the accused pleads guilty, especially if he is an ignorant person, the trial court must be sure the defendant fully understood the nature of the charge and the punishment. While not mandatory by statute, it is prudent and advisable for the court to call witnesses to establish guilt and the degree of culpability. This procedure aids not only the trial judge but also the Supreme Court in its automatic review of death penalty cases.
The Court found the record inadequate. Apart from the trial court’s recitals in its decision, no evidence established with sufficient certainty that Castanio truly comprehended the meaning and consequences of his plea. The belated attempt to hold a hearing was unavailing. Therefore, to ensure due process, the case was ordered remanded. The trial court must conduct a new hearing where the accused, assisted by counsel, can be examined. The court should take testimony to satisfy itself regarding the accused’s understanding of his original plea. Should the accused desire to change his plea, the trial court must consider it, set aside the 1972 judgment, and proceed to trial based on the evidence.